District of Columbia Public Schools: Student Enrollment Count Remains Vulnerable to Errors

Published by the Government Accountability Office on 1997-08-21.

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

                  United States General Accounting Office

GAO               Report to the Chairman, Subcommittee
                  on the District of Columbia, Committee
                  on Government Reform and Oversight,
                  House of Representatives

August 1997
                  DISTRICT OF COLUMBIA
                  PUBLIC SCHOOLS
                  Student Enrollment Count
                  Remains Vulnerable to

      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division


      August 21, 1997

      The Honorable Thomas M. Davis
      Chairman, Subcommittee on the District of Columbia
      Committee on Government Reform and Oversight
      House of Representatives

      Dear Mr. Chairman:

      The District of Columbia Public Schools (DCPS) is one of the largest public
      school districts in the country—ranked 32nd in school year 1993-94,1 on
      the basis of student count, out of nearly 15,000 districts. During school
      year 1996-97, DCPS operated 158 elementary and secondary schools and
      reported its official student enrollment to be 78,648. DCPS’ budget was
      more than $570 million in fiscal year 1997—16 percent, or $90 million, of
      which came directly from federal government programs providing grants
      and funds.2

      As early as school year 1989-90, questions about the accuracy of DCPS’
      enrollment count arose when the previous year’s enrollment count was
      approximately 6,400 fewer students than had been reported. Even before
      school year 1989-90, school system figures were at odds with other
      independent counts. In 1984 and again in 1986, the Department of
      Education’s Office for Civil Rights released figures differing from DCPS’
      official counts by more than 5,000 and 2,000, respectively. More recent
      critics have found discrepancies when comparing the reported enrollment
      with census estimates and with the District’s general population decline.
      In addition, various reviewers and auditors have questioned several
      aspects of DCPS’ enrollment count process.

      These criticisms raise concern because an accurate enrollment count is
      the cornerstone of a school district’s financial needs assessments.
      Although in the past DCPS did not receive funds on the basis of the number
      of students enrolled, new budget initiatives will soon directly link DCPS’
      funding to school enrollment. Consequently, a valid enrollment count
      process and an accurate count are critical to DCPS’ district- and school-
      level planning, staffing, funding, and resource allocation.

       The latest year for which official rankings are available.
       The annual appropriation act passed by the Congress provided the rest; the act makes funds
      (including locally generated revenues and the federal payment) available to the District of Columbia
      for obligation and expenditure.

      Page 1                                                   GAO/HEHS-97-161 DCPS Enrollment Count

                   In response to these issues, you asked us to examine the enrollment count
                   process that DCPS used in school year 1996-97 to determine whether the
                   process appeared sufficient to produce an accurate count. In addition, you
                   asked us to examine enrollment count processes used by some other
                   urban school systems and to determine the role of the U.S. Department of
                   Education’s Inspector General in preparing DCPS’ official enrollment count
                   for school year 1996-97.

                   To conduct this review, we obtained relevant documents from and we
                   interviewed DCPS administrative staff, city officials, officials in other urban
                   school districts3 and their state departments of education, officials in the
                   Department of Education, and education experts. To gain an
                   understanding of the process’ implementation, we visited 15 DCPS
                   elementary and secondary schools, randomly selected by school level
                   (elementary, junior high or middle school, and senior high) and city
                   quadrant (Northeast, Northwest, Southeast, and Southwest).4 During our
                   school visits, we interviewed principals, school administrative staff, and
                   teachers and reviewed selected documents. Further information on our
                   scope and methodology appears in appendix I.

                   Even though DCPS changed parts of its enrollment count process in school
Results in Brief   year 1996-97 to address criticisms, the process remains flawed. Some of
                   these changes, such as the use of an enrollment card to verify attendance,
                   increased complexity and work effort but did little to improve the count’s
                   credibility. Errors, including multiple enrollment records for a single
                   student, remained in the Student Information System (SIS), but DCPS had
                   only limited mechanisms for correcting these errors. For example, though
                   Management Information Services (MIS) personnel maintain SIS, they have
                   no authority to correct errors. Furthermore, DCPS’ practice of allowing
                   principals to enroll unlimited out-of-boundary students increases the
                   possibility of multiple enrollment records for one student.

                   Problems also persisted in the critical area of residency verification. In
                   school year 1996-97, schools did not always verify student residency as

                    The other districts were Boston and Chelsea, Massachusetts; Fairfax County and Arlington County,
                   Virginia; and Montgomery County and Prince George’s County, Maryland. We interviewed officials and
                   examined documents they provided, but we did not confirm whether their processes were
                   implemented as they described.
                    The schools visited were Anacostia High School, Bowen Elementary School, Coolidge High School,
                   C.W. Harris Elementary School, Deal Junior High School, Eliot Junior High School, Miner Elementary
                   School, Montgomery Elementary School, Noyes Elementary School, Phelps Career High School,
                   Randle Highlands Elementary School, Roosevelt High School, Terrell Elementary School, Thomson
                   Elementary School, and Tubman Elementary School.

                   Page 2                                               GAO/HEHS-97-161 DCPS Enrollment Count

             required by DCPS’ own procedures. Proofs of residency, when actually
             obtained, often fell short of DCPS’ standards. Moreover, Central Office staff
             did not consistently track failures to verify residency. Finally, school staff
             and parents rarely suffered sanctions for failure to comply with the
             residency verification requirements.

             In addition, the pupil accounting system failed to adequately track
             students. SIS allowed more than one school to count a single student when
             the student transferred from one school to another. In addition, schools
             did not always follow attendance rules, and SIS lacked the capability to
             track implementation of the rules. Furthermore, some attendance rules, if
             implemented, could have allowed counting of nonattending students.

             Other school districts report that they use several approaches to control
             errors, such as the ones we identified in DCPS, and to improve the accuracy
             of their enrollment counts. These include using centralized enrollment and
             pupil accounting centers and a variety of automated student information
             system edits and procedures designed to prevent or disallow pupil
             accounting errors before they occur.

             Finally, the recently enacted District of Columbia School Reform Act of
             19955 requires the enrollment count process to produce enrollment
             numbers for nonresidents and students with special needs. DCPS (acting on
             behalf of the District of Columbia Board of Education) and the District of
             Columbia Financial Responsibility and Management Assistance Authority
             (Authority) are not in compliance with requirements of this new law,
             including a specified annual report on the enrollment count and its
             subsequent independent audit. The U.S. Department of Education helped
             DCPS develop its Request for Proposals (RFP) for the independent audit of
             the enrollment count for school year 1996-97, but it had no role in
             preparing DCPS’ official enrollment count for school year 1996-97. The
             Authority subsequently decided, however, that auditing the count for
             school year 1996-97 would be counterproductive.

             Unlike other U.S. school districts, DCPS, due to its location in the nation’s
Background   capital, has a unique administrative environment. Because Washington,
             D.C., is not located in a state, DCPS does not benefit from the oversight and
             assistance often provided by states. Furthermore, recent organizational
             changes in both the city and its school system have changed
             administration of the schools.

              Title II of P.L. 104-134 (1996).

             Page 3                                    GAO/HEHS-97-161 DCPS Enrollment Count

                        To reform the District’s school system, the Congress recently passed the
                        District of Columbia School Reform Act of 1995, which includes
                        requirements for counting District students. Counting student enrollment,
                        a process involving several interconnected elements, is usually
                        fundamental to assessing funding needs and required of most other U.S.
                        school districts. DCPS’ enrollment count process in school year 1996-97 was
                        centered in the local schools and modified somewhat to address

DCPS’ Administrative    DCPS  lacks the state-level oversight that most other school districts in the
Environment Is Unique   country have. The state’s role in school operations is an important one.
                        States generally provide guidance to their school districts on important
                        issues, including student enrollment counts. The state determines the rules
                        to be used in the enrollment count—who should be counted, by what
                        method, and when. States also distribute state and federal funds to their
                        districts, usually on the basis of enrollment, and they routinely audit
                        various school district operations, including the enrollment count.

                        The governance of DCPS had been performed for many years by an elected
                        Board of Education. In November 1996, however, the specially appointed
                        District of Columbia Financial Responsibility and Management Assistance
                        Authority (Authority) declared a state of emergency in DCPS and
                        transferred DCPS management—until June 30, 2000—to the Authority’s
                        agents, a nine-member, specially appointed Emergency Transitional
                        Education Board of Trustees.6 In so doing, the Authority transferred to the
                        Board of Trustees “. . . all authority, powers, functions, duties,
                        responsibilities . . .” of the former Board of Education7 (with some
                        exceptions not relevant to this report). Meanwhile, the Authority also
                        replaced DCPS’ superintendent with a Chief Executive Officer/
                        Superintendent. These changes have resulted in a shift of control from
                        elected officials toward those appointed for a specific purpose: to reform
                        the system. Early reform initiatives have included the administrative
                        reorganization of DCPS and the closure of 11 schools.

                        Even before the Authority’s takeover of DCPS, the Congress, relying on its
                        plenary power to legislate for the District of Columbia, acted directly to
                        reform DCPS. In April 1996, the Congress passed the District of Columbia
                        School Reform Act of 1995, calling for the calculation of the number of

                         The president of the Board of Education is one of nine members of the Board of Trustees.
                         The Board of Education retained an advisory role on general educational policy and remains the
                        chartering authority for Public Charter Schools under the School Reform Act.

                        Page 4                                                GAO/HEHS-97-161 DCPS Enrollment Count

                                 students enrolled in DCPS. The law requires the District of Columbia Board
                                 of Education8 to do the following:

                             •   calculate by October 15 of each year the number of students enrolled in
                                 the District’s public schools and students whose tuition in other schools is
                                 paid by DCPS funds, including students with special needs9 and nonresident
                                 students, in the following categories by grade level if applicable:
                                 kindergarten through grade 12, preschool and prekindergarten, adult
                                 students, and students in nongrade level programs;
                             •   calculate the amount of fees and tuition assessed and collected from
                                 nonresident students in these categories;
                             •   prepare by October 15 and submit to the Authority, the Comptroller
                                 General of the United States, appropriate congressional committees, and
                                 others an annual report summarizing those counts; and
                             •   arrange with the Authority to provide for the conduct of an independent
                                 audit of the count. Within 45 days of the Authority’s receipt of the annual
                                 report—or as soon thereafter as is practicable—the Authority is to submit
                                 the independent audit report to the appropriate congressional committees.

Most School Districts Must       The requirement to count students is common to most other U.S. school
Count Student Enrollment         districts. Forty-one of the 50 states10 use some type of direct student count
                                 to assess resource needs and to distribute state funds to their school
                                 districts. Enrollment counts also usually determine budgets and resource
                                 allocations to the individual schools.

                                 Three basic methods are used for counting enrollment. One method—
                                 called Enrolled Pupils (often called ENR)—counts all enrolled students on
                                 a specified day of the year. Definitions of “enrolled students” vary among
                                 districts, but they usually include elements of attendance. That is, students
                                 must be in attendance at least once during some preceding time period.
                                 ENR is used by 12 states and the District of Columbia. Another similar
                                 method is called Pupils in Average Daily Membership (often called ADM).
                                 This method, used by 22 states, calculates the average of total enrollment

                                  The Resolution that established the Board of Trustees specifically transferred all Board of Education
                                 responsibilities regarding the District of Columbia School Reform Act to the newly created Board of
                                  The law defines a “student with special needs” as a student who is a child with a disability under the
                                 Individuals With Disabilities Education Act, or a student who is an individual with a disability under
                                 the Rehabilitation Act of 1973 as amended.
                                  Seven states use teacher or instructional units rather than student count, and two states use other
                                 methods to distribute funds.

                                 Page 5                                                  GAO/HEHS-97-161 DCPS Enrollment Count

figures over a specified time period.11 A third method, called Pupils in
Average Daily Attendance (often called ADA), calculates the average total
daily attendance over a specified time period. Seven states use this

Enrollment counts may occur several times throughout the school year in
response to both state and local information needs and may use different
counting methods depending on the purpose of the count. For example,
officials in one district reported that they perform a count about 5 days
after school opens, using the ENR method. The district uses this count to
make final adjustments to school-level resource allocations for the current
school year. On September 30, the district conducts the first of three
state-required enrollment counts, also using the ENR method. The state
uses this count to assess compliance with state quality standards (such as
pupil/teacher ratios) and to estimate enrollment before the March 31
count. On March 31, the district conducts the second state-required count,
this time using the ADM method. The state uses this count to distribute
state funds. Finally, the district conducts the third state-required
enrollment count at the end of the school year, also using the ADM method.
The state uses this count as a final report on enrollment for the entire
school year. In addition to fulfilling reporting requirements, the school
district uses the state-required enrollment counts for local planning and
monitoring purposes.

States vary in their approach to monitoring and auditing their districts’
enrollment counts. Some states do little monitoring or auditing of their
districts’ counts, while others stringently monitor and audit. For example,
one state simply reviews district enrollment reports for the fall and spring
and contacts districts if large discrepancies exist. In contrast, another
state not only conducts an electronic audit of its districts’ spring and fall
official enrollment counts, but also visits districts and examines a random
sample of student records in detail. School district officials in this state
reported that the state withdraws from its districts state funds paid for
students improperly enrolled or retained on the rolls.

Regardless of when the count is performed or by what method, whether
audited or not, accuracy is critical. A student count may be inaccurate if it
has problems in any of at least three critical areas: enrollment, residency
verification, and pupil accounting. Enrollment and residency verification
take place when a student enters the school system. They determine a
student’s initial eligibility and therefore who may potentially be included

  Maryland and Massachusetts require ENR; Virginia requires ADM.

Page 6                                              GAO/HEHS-97-161 DCPS Enrollment Count

                          in the count. Pupil accounting refers to the tracking of students after initial
                          enrollment. Monitoring student attendance, status, and transfers in and out
                          of school are all part of pupil accounting, which often involves an
                          automated student database. The pupil accounting system provides the
                          basis for determining continued eligibility to be counted—based upon a
                          student’s attendance—and it helps determine which school may count a
                          particular student in its enrollment.

Accuracy of DCPS’         Critics have often charged that the District’s reported official enrollment
Enrollment Count Has      numbers have been overstated. One reviewer asserted, for example, that
Been Questioned           results of the 1990 U.S. census suggest that the District’s school-age
                          population in 1990 might have been as much as 13,000 less than DCPS’
                          official enrollment count. Subsequent reviewers, including a certified
                          public accounting firm, the Office of the District of Columbia Auditor, and
                          us, examined the process that DCPS used to count pupils in school years
                          1994-95 and 1995-96 and found flaws. These flaws included DCPS’ lack of
                          documentation to support enrollment status and lack of sanctions if false
                          enrollment information was provided. These reviewers also reported that
                          DCPS lacked adequate procedures to verify residency and that the student
                          database had errors, including duplicate records, incomplete transfers,
                          and incorrect enrollment status. For a more detailed discussion of audit
                          findings and recommendations, see appendix II.

DCPS’ Enrollment Count    DCPS’ process for enrolling, verifying residency of, and tracking students
Process in School Year    remained centered in the local school in school year 1996-97, while central
1996-97 Remained          office staff monitored portions of the process. To respond to past
                          criticisms, DCPS instituted some changes for school year 1996-97, including
Centered in the Local     new forms, residency verification procedures, and additional preparatory
Schools                   counts. The actual official enrollment count was done manually, and
                          school principals were ultimately responsible for ensuring the accuracy of
                          their schools’ counts.

Local Schools Conducted   DCPS’ local schools conducted all enrollment activities in school year
Enrollment Activities     1996-97 for new and returning students, and the schools’ principals made
                          all determinations about enrollment eligibility. Principals were allowed to
                          enroll students who lived outside school boundaries without limitation.
                          Principals could also temporarily enroll students who had not provided
                          evidence of meeting eligibility criteria, including health certificates and
                          proofs of District of Columbia residency. Upon completion of initial
                          paperwork, the schools’ data entry clerks created an electronic record for

                          Page 7                                    GAO/HEHS-97-161 DCPS Enrollment Count

each newly enrolled—or temporarily enrolled—student in SIS.12 The
system maintained records for returning students from the previous
school year, and the records were updated during the summer with
promotion information. Similarly, withdrawals were processed during the
summer, and these records were removed from the schools’ rolls. Figure 1
shows the enrollment count process for school year 1996-97.

 SIS has been used for the past 3 years, replacing the former Student Information Membership System
(SIMS). It contains biographical, demographic, academic, and status information on each student
enrolled in DCPS.

Page 8                                               GAO/HEHS-97-161 DCPS Enrollment Count

Page 9     GAO/HEHS-97-161 DCPS Enrollment Count

Figure 1: DCPS Enrollment Count Process for School Year 1996-97
                         Summer                                                             September
                          1996         3         4    5    6       7        8    9     10      11       12   13     14   15      16   17   18   19

                                                                                      Transfers/New Students

                                  Homeroom                         SIS                       SIS                        SIS                     SIS
                    Returning                                                                                                                Rosters
                                    Rosters                        File                      File                       File
                     Student                                                                                                                Generated
                                   Prepared                     Updated                   Updated                     Updated
                     Records                                                                                                                     for
                                                                to Show                  to Convert                    With
                   Updated as                                                                                                               Preliminary
                                  SIS Shows                       New                   "No-Shows"                   Addresses
                  of September                                                                                                                Count
                                  All Students                  Enrollees               to "Inactive"
                                  as "Active"
    School                                                                                  Student Residency
                                         Cards                                              Forms Completed
                                       Completed                                              and Submitted
                                                                                               With Proofs
                                                               Attendance Rosters
                                                                  Reviewed for

                                                                       School Provides Daily Membership Counts
                                                                                    to Central Office

                                                                                     Initial Monitoring

                                                     Page 10                                                      GAO/HEHS-97-161 DCPS Enrollment Count

                       September                                                                         October                              December
             20       21   22      23       24     25      26      27     28    29    30     1      2       3        4   5        8       9       10       11     12

                                        Transfers/New Students

            File                                                    SIS
         Reconciled                                               Rosters                                Official
           With                                                  Generated                               Count
         Enrollment                                                 for                                 Performed
         Cards and                                                Official
          Updated                                                  Count

  Preliminary                                                                                                                  Sept. 3 - First Day of School
Count Performed                                                                                                                Sept. 19 - Preliminary Count
   Using SIS                                                                                                                   Oct. 3 - First Official Count
    Rosters                                                                                                                    Dec. 11 - Official Count Released

Preliminary Counts          Residency Forms                                                         Official Count
    Forwarded                 Forwarded                                                              Forwarded

                                                                                                          Office                                        Central
                                                                                                        Reconciled                                      Office
                                                                                                           and                                         Released
                                                                                                        Aggregated                                      Count

                                          Interim Enrollment Monitoring                                                       Final Enrollment Monitoring

                                                                                                                             Residency Validation Visits

                                                                New Procedures in School Year 1996-97

                                                        The process in school year 1996-97 incorporated the use of a new
                                                        enrollment card designed to address auditors’ concerns about validating
                                                        enrollment status. Students were to complete two copies of the enrollment

                                                        Page 11                                                      GAO/HEHS-97-161 DCPS Enrollment Count

                                card on the first day of attendance, and teachers were to sign and certify
                                the cards. A completed card was to serve as proof that a child had
                                appeared the single day required to be considered enrolled. In addition to
                                serving as proof of enrollment status, the card was to be used to update

Process Required Evidence of    In addition to the enrollment card, DCPS’ enrollment process for 1996-97
Residency                       required all students to provide evidence of District of Columbia
                                residency. If the student provided no evidence, DCPS’ rules allowed the
                                student to enroll, but the student was to be assessed tuition. Tuition for a
                                full-time program for school year 1996-97 ranged from $3,349 to $7,558,
                                depending on grade level.

                                Providing evidence of District of Columbia residency was required as part
                                of revised DCPS procedures for school year 1996-97 to answer critics who
                                charged that DCPS’ process for verifying residency was inadequate. In
                                previous years, only students entering DCPS schools for the first time would
                                have been required to submit proof of residency. A new form, the Student
                                Residency and Data Verification Form, which had been piloted at selected
                                schools during the previous school year, was to be completed for all
                                students during school year 1996-97. Students were expected to have their
                                parents or guardians complete the form and return it to the school with
                                proofs of residency attached. Schools were to give students 3 days to
                                complete and submit the form and proofs. Within 10 days, the school was
                                to provide one copy of the form to the Nonresident Tuition Enforcement
                                Branch of the Central Office along with a list of those students for whom
                                residency had not been verified. The Nonresident Tuition Enforcement
                                Branch was responsible for assessing and collecting tuition.

Pupil Accounting Also Resided   In addition to enrollment and residency verification procedures, local
in the Local Schools            schools also tracked student attendance, status, and transfers in school
                                year 1996-97. Each of DCPS’ schools had online access to school data, and
                                the schools’ data entry personnel (or enrollment clerks) were responsible
                                for ensuring data were accurate and up to date. The MIS Branch, however,
                                in the Central Office, managed the overall database.

                                Classroom or homeroom teachers took attendance once a day, and data
                                entry staff recorded it in SIS. Transfers were often done electronically, with
                                transfer procedures initiated by the losing school and completed by the
                                gaining school, although a manual back-up transfer process was also

                                Page 12                                  GAO/HEHS-97-161 DCPS Enrollment Count

Monitoring Activities Included   Monitoring activities for school year 1996-97 focused exclusively on
Use of Enrollment Cards and      overseeing the schools’ implementation of the enrollment card and on
Identifying Nonresidents         identifying nonresidents. During the early part of the school year, DCPS’
                                 Central Office staff visited each of the schools three times to monitor
                                 enrollment cards. Eighteen members of the Central Office staff were
                                 temporarily reassigned to monitor the cards. Staff paid the first monitoring
                                 visit within the first 2 weeks of school and focused on the extent to which
                                 schools were following the process, that is, distributing and completing
                                 enrollment cards and filing them in the appropriate locations. Staff paid
                                 the interim monitoring visit before the official enrollment count and
                                 manually tallied students, comparing the enrollment cards, SIS reports, and
                                 the preliminary count documents. Staff paid the final monitoring visit after
                                 the October 3 count and were to verify that names on the enrollment cards
                                 matched those on SIS homeroom rosters.

                                 Nonresident students of the District of Columbia were to be identified
                                 through local schools’ monitoring of the completed data verification
                                 forms. The Nonresident Tuition Enforcement Branch was to investigate
                                 cases the schools identified. In addition, staff from this branch were to
                                 visit the schools to survey cars transporting students to and from school,
                                 identifying all out-of-state license plates. The monitors were also to review
                                 enrollment cards and residency verification forms to determine if the
                                 forms indicated residency issues. The branch was to investigate all
                                 identified cases and assess tuition for students found not meeting the
                                 District’s residency requirements.

DCPS Used ENR to Count           As previously mentioned, for school year 1996-97, DCPS used the ENR
Students                         method to count its students—counting all enrolled students on a single
                                 day—October 3, 1996. Students did not have to attend school on this day
                                 to be included in the count because enrollment records were counted—
                                 not actual students. DCPS defined an “enrolled student” as any student who
                                 had appeared at school at least once—and who had not withdrawn from
                                 DCPS—between the beginning of the school year on September 3, 1996, and
                                 October 3, 1996, the day of the count.

                                 DCPS’October 3, 1996, count was conducted manually by each homeroom
                                 teacher using homeroom rosters prepared from SIS. School staff compiled
                                 the count, classroom by classroom, and recorded the numbers on the
                                 school’s official report. The Central Office received the schools’ reports,
                                 and schools’ data were aggregated by the Office of Educational

                                 Page 13                                  GAO/HEHS-97-161 DCPS Enrollment Count

                      Accountability (OEA),13 which prepared the official enrollment report.14
                      Each school’s principal was to ensure not only the accuracy of the
                      school’s manual count, but also the enrollment, residency, and pupil
                      accounting data that supported it. DCPS’ policy for the October 3, 1996,
                      count called for unspecified rewards and sanctions to be applied on the
                      basis of the extent to which staff maintained and reported accurate,
                      up-to-date information.

                      Beyond the official October count, DCPS also performed other counts
                      throughout the year using this same process. These included official
                      counts in December and again in February. The February count aided in
                      computing projections for school year 1997-98. In addition to these counts,
                      DCPS began two new preparatory counts this year. Each school took daily
                      enrollment counts and communicated them by telephone to the Central
                      Office every morning for the first 11 days of the school year. In addition, in
                      September, each school completed a preliminary count using forms
                      established for the official October 3 count.

                      DCPS’ new student enrollment card was intended to document that
School Year 1996-97   students had met the 1-day attendance requirement for inclusion in the
Enrollment Process    official enrollment count. Although the card may have met this
Changes Did Not       requirement in some respects, it appears to have burdened both school
                      and DCPS staff and may not offer much advantage over more traditional
Ensure Accuracy       methods of documenting attendance, such as teachers’ attendance
                      tracking. Perhaps even more importantly, the card alone did not ensure
                      that enrollment records were correct before the count. The card did not
                      address a critical problem—one revealed by prior audits—a lack of
                      internal controls of the student database. This problem allowed multiple
                      records to be created for a single student. Furthermore, DCPS continued to
                      include in its enrollment some categories of students often excluded in
                      official enrollment counts used for funding purposes in other states. In
                      contrast to DCPS procedures, officials in other school districts reported
                      using various strategies for ensuring accuracy and minimizing duplicate

                       OEA was dissolved in winter 1997 by the DCPS’ new Chief Executive Officer/Superintendent as part
                      of his administrative reorganization. Many of OEA’s functions were transferred to the office of the
                      Chief Academic Officer.
                       District of Columbia Public Schools, FY 1996-97 Official Membership, October 3, 1996, DCPS
                      (Washington, D.C.: Dec. 1996).

                      Page 14                                              GAO/HEHS-97-161 DCPS Enrollment Count

Enrollment Card Appears   Teachers and school staff reported that DCPS’ new enrollment card was
to Be Burdensome and      burdensome and difficult to implement. Each child, on the first day of
Inefficient               attendance, had to complete and sign two separate copies15 of the card.
                          However, many students—primarily the very young, disabled, or non-
                          English speaking—could not complete the card themselves because they
                          could not read or write at all or do so in English. In these cases, teachers
                          had to complete the enrollment cards, although the students were asked to
                          sign the cards when possible. Teachers, particularly in the primary grades,
                          reported that completing the cards was troublesome for them, adding to
                          their paperwork burden. Furthermore, the legitimacy of a child’s signature
                          as a method of validation—particularly when the child cannot read or
                          write—is questionable.16

                          In addition, the enrollment card did not contain vital enrollment
                          information needed by the schools, such as emergency contact numbers.
                          Consequently, it could not substitute for other enrollment forms that
                          schools had been using. Several of the schools we visited augmented the
                          enrollment card with other forms to obtain needed information.
                          Consequently, the busy school staff had to complete and manage multiple
                          forms to collect and maintain basic enrollment data.

                          Moreover, the procedures that DCPS established for completing the
                          enrollment card were difficult to implement after the first days of the
                          school year. The procedures, which required the teacher to certify the
                          student’s signature, were designed for the initial few days of school when
                          an entire class enrolled together and could complete the form in the
                          teacher’s presence. No provision had been established for students
                          arriving later, who normally enroll at the school office. School staff in the
                          schools we visited reported that they could not sign the card for the
                          teacher, and obtaining the teacher’s signature and certification for these
                          late enrollments was sometimes difficult. As a result, the process
                          sometimes failed when enrollment cards for late enrollees were not
                          completed or signed and certified by teachers.

                          Finally, DCPS officials reported that Central Office monitoring for
                          implementation of the new enrollment card was labor intensive.
                          Enrollment card monitoring efforts did not use statistical sampling.
                          Instead, we were told, monitors visited all the schools on three separate

                           One of the cards was to stay with the teacher, and one was forwarded to the school’s office to be
                          maintained in files by classroom.
                           The six districts we visited have similar attendance requirements but do not require this type of
                          validation, depending instead upon attendance data to prove that the student was present.

                          Page 15                                                GAO/HEHS-97-161 DCPS Enrollment Count

                            occasions, often reviewing 100 percent of the enrollment records. To
                            perform this task, monitoring teams were formed, without regard to their
                            normal responsibilities, from available staff within the former OEA,
                            according to DCPS officials. During our review, we could not confirm the
                            extent of these enrollment card monitoring visits because DCPS could not
                            provide us with any of the monitoring reports prepared on the basis of
                            these visits.

Lack of Internal Controls   The procedures that DCPS used for enrolling students in school year
Allowed Multiple            1996-97 allowed multiple records to be entered into SIS for a single student.
Enrollment Records          When school staff entered a new record, the SIS processing procedure
                            automatically queried the database for any matching names and dates of
                            birth. If a match occurred—as would be the case if the student had
                            previously enrolled in a DCPS school—SIS informed the person entering the
                            data that a record already existed for an individual with that name and
                            date of birth. SIS, however, also provided the option of overriding the
                            system and creating a new record for the student. DCPS officials reported
                            that some data entry personnel were choosing this override capability and
                            creating the new record. With safeguards overridden and additional
                            records created, two schools could have each had access to a separate
                            record for the same individual, allowing both schools to count the student.

                            DCPS’  mechanisms for resolving this error were limited. Although Central
                            Office MIS personnel maintained SIS, they had no authority to correct the
                            errors once detected. Only the local school had such authority. MIS
                            personnel had limited influence over the schools to ensure that
                            corrections were made quickly and accurately, according to DCPS officials.
                            Furthermore, while duplicate record checks were done, officials told us,
                            the checks were not done on a regular, routine schedule. In addition,
                            individuals who had helped with data quality control in the past as well as
                            those who had monitored attendance were moved in early 1997 to
                            facilities without office telephones or data lines.17

                            DCPS’ practice of allowing schools to enroll, without restriction, students
                            who live outside school attendance boundaries increased the possibility of
                            a student’s having multiple enrollment records for school year 1996-97.
                            Students did not have to enroll in the school serving the geographic area
                            where they lived but could enroll in any DCPS school if the principal
                            allowed. For example, a student could have gone first to the school

                             DCPS officials told us that they had no plans to relocate the personnel or install telephone lines
                            before the collocation of DCPS offices in the spring of 1998. Staff members, instead, will continue to
                            be expected to travel to a local school when they need to perform SIS data runs.

                            Page 16                                                 GAO/HEHS-97-161 DCPS Enrollment Count

                           serving his or her area, filled out an enrollment card, and been entered into
                           SIS. Subsequently, the student may have gone to another school, filled out
                           another enrollment card, and—if the person entering this record in SIS
                           chose to override the safeguard—been entered into SIS a second time. In
                           addition, some principals reported that schools actively sought to attract
                           out-of-boundary students to increase their enrollment.

Enrollment Procedures      DCPS’ official enrollment count of 78,648 included not only regular
Allow Count of Students    elementary and secondary students, but also other categories of students
Not Counted in Some        excluded from enrollment counts in other districts when the counts are
                           used for funding purposes. For example, DCPS included in its enrollment
Other Districts            count students identified as tuition-paying nonresidents of the District of
                           Columbia and students above and below the mandatory age for public
                           education in the District, including Head Start participants,18
                           prekindergarten students (age 4), preschool students (age 0 to 3), and
                           some senior high and special education students aged 20 and older.19 In
                           contrast, the three states we visited reported that they exclude any student
                           who is above or below mandatory school age or who is fully funded from
                           other sources from enrollment counts used for funding purposes.
                           Furthermore, even though the District of Columbia Auditor has suggested
                           that students unable to document their residency be excluded from the
                           official enrollment count, whether they pay tuition or not, DCPS included
                           these students in its enrollment count for school year 1996-97.

Other Districts Report     In contrast with the DCPS process, students in the Boston and Chelsea,
Using Various Methods to   Massachusetts, school districts enroll at central Parent Information
Help Improve Enrollment    Centers (PIC), which are separate and independent from the schools,
                           officials told us. Individual schools in these two districts cannot enroll
Accuracy                   new students, we were told. All enrollment activities, including assignment
                           of all students to schools, take place at PICs. Boston’s PICs were established
                           as a key part of the U.S. District Court’s desegregation plan to alleviate the
                           Court’s concerns about the accuracy of Boston’s reported enrollment
                           numbers and to satisfy the Court’s requirements for credibility and
                           accountability in pupil enrollment, assignment, and accounting.

                           Centralizing student enrollment at PICs has helped reduce errors,
                           according to officials in both districts. For example, staff in Boston have

                             Head Start has its own funding source.
                             The Reform Act requires separate reporting of some of these groups but does not require that they be
                           included in aggregate counts.

                           Page 17                                               GAO/HEHS-97-161 DCPS Enrollment Count

                      specialized in and become knowledgeable about the process. Limiting
                      access to the student database has also helped to reduce errors. For
                      example, in Boston, only six people may enter data into the database.
                      Furthermore, PICs prevent students from being enrolled at two or more
                      schools simultaneously, reducing duplicate counting and preventing
                      schools from inflating their enrollment.

                      In the other four districts we visited, schools—rather than a central
                      site—usually handle student enrollment,20 but they use other safeguards.
                      To enroll, a student goes to the school serving the geographic area in
                      which he or she lives. Out-of-boundary enrollment is not usually allowed.21
                      In addition, officials in all four of these districts reported having student
                      database safeguards to aid enrollment accuracy. For example, all four
                      districts have procedures and edits in their student databases that
                      automatically block the creation of duplicate enrollment records. If an
                      enrolling student has attended another school in the district, these
                      procedures will not allow a new record to be created once the old record
                      has been located. School staff, officials told us, cannot override this
                      blocking mechanism. In addition, Prince George’s County has a procedure
                      in its student database that automatically checks student addresses with
                      school attendance boundaries as enrollment information is entered. If the
                      address falls outside the enrolling school’s boundaries, the database
                      blocks enrollment.

                      During school year 1996-97, District of Columbia schools had features that
New Residency         attracted nonresidents. Elementary schools in the District had free all-day
Verification          prekindergarten and kindergarten, and some elementary schools had
Procedures Were Not   before- and after-school programs at low cost. One school we visited had
                      before- and after-school care for $25 per week. This program extended the
Completely            school day’s hours to accommodate working parents—the program began
Implemented           at 7 a.m. and ended at 6 p.m. In addition, several high schools had highly
                      regarded academic and artistic programs; and some high schools had
                      athletic programs that reportedly attracted scouts from highly rated
                      colleges. Furthermore, students could participate in competitive athletic

                       Officials in the Fairfax County school district said that new students with limited-English proficiency
                      and new students with disabilities enroll and verify residency at central service centers designed to
                      help students with special needs.
                        Arlington County school district officials told us that after enrolling, their students are allowed to
                      seek transfers to out-of-boundary schools for academic reasons. Schools may accept such transfers as
                      long as they do not exceed 4 percent of their total enrollment. Fairfax County and Prince George’s
                      County also allow attendance at out-of-boundary schools under special circumstances, with
                      permission of the central administration.

                      Page 18                                                 GAO/HEHS-97-161 DCPS Enrollment Count

                           programs until age 19 in the District, compared with age 18 in some nearby

                           DCPS established new procedures for school year 1996-97 to detect
                           nonresidents and collect tuition from those who attended DCPS schools,
                           but both school and Central Office staff failed to implement the new
                           procedures completely.22 In addition, DCPS failed to monitor and enforce its
                           new procedures effectively.

Schools Failed to Verify   Most of the schools we visited failed to comply with the new residency
and Report Residency for   verification process. As discussed previously, all students’ parents or legal
All Students as Required   guardians had to complete a Student Residency and Data Verification
                           Form (residency form) and provide at least two proofs of residency.
by DCPS Policy             Students were told that failure to provide either the completed residency
                           form or proofs would result in an investigation of their residency, and, if
                           appropriate, either tuition payments or exclusion from DCPS. Most of the
                           schools we visited, however, did not obtain completed residency forms for
                           all their students. In fact, only 2 of the 15 schools had—or reported
                           having—residency forms for 100 percent of the student files we reviewed.

                           In addition, schools did not collect all required proofs of residency.
                           Students and their families presented two proofs of residency in only
                           isolated cases, and many students submitted no proofs. In many other
                           cases, the proofs that the schools collected did not meet the standards
                           established by DCPS and printed on the residency form. Although the
                           residency form specified proofs of residency, such as copies of deeds,
                           rental leases, utility bills, or vehicle registrations, as acceptable, schools
                           sometimes accepted proofs such as newspaper or magazine subscriptions,
                           copies of envelopes mailed to the student’s family, stubs from paid utility
                           bills with no name attached, and informal personal notes (rather than
                           leases or rental agreements) from individuals from whom the family
                           reportedly rented housing. We also found some instances in which the
                           names or addresses on the proof did not match those on the form. School
                           staff often complained to us about the difficulty they had trying to get
                           students to return completed residency forms and proofs. Some
                           acknowledged that they placed little emphasis on this effort.

                           Schools we visited also varied in their compliance with the requirements
                           to report residency issues to OEA. Schools were supposed to forward
                           copies of all students’ completed residency forms to OEA. These copies

                             Audit reports of the Oct. 1995 count also criticized DCPS for failure to verify student residency.

                           Page 19                                                  GAO/HEHS-97-161 DCPS Enrollment Count

                          were to be attached to a list of students whose residency was considered
                          questionable. Some schools sent copies of their student residency forms
                          along with the list as required. Others sent the proofs with the forms. At
                          least six schools sent no verifications of residency to the Central Office.

                          Some of these implementation issues may have resulted from poorly
                          specified requirements and procedures. For example, though DCPS officials
                          reported to us that the requirements were for at least two proofs of
                          residency, we found no written documentation communicating to the
                          school staff or to the students a requirement for more than one proof. DCPS
                          officials also gave us conflicting information about the number of proofs
                          required. At one meeting, we were told that three proofs were required; at
                          a later meeting, that two to three were required.

                          Similarly, DCPS’ guidance to the schools did not specify how the schools
                          were to maintain their students’ completed residency documentation—or
                          even exactly what documentation was to be maintained. Consequently,
                          schools’ maintenance of residency documents varied considerably. For
                          example, about one-third of the schools we visited maintained the
                          residency forms alphabetically; the remaining schools grouped them by
                          classroom. The schools’ disposition of the proofs of residency varied even
                          more. Eight schools filed proofs of residency with the students’ completed
                          residency forms; one filed the proofs in the students’ permanent
                          (cumulative) record folder; one filed them either with the completed form
                          or in the folder; one placed all proofs in a file drawer without annotating
                          them to permit subsequent identification of the student to whom they
                          belonged; two forwarded all proofs to OEA, along with copies of the
                          completed form; and two schools had no proofs at all for the student
                          records we reviewed. And, because procedures did not provide for the
                          schools to document the proofs on the residency forms, schools not
                          retaining the proofs with the forms could not demonstrate that they had
                          adequately verified residency. Other audits of schools’ compliance with
                          residency verification would face similar obstacles because of the schools’
                          inability to link student records with proof of residency.

Central Office Did Not    Monitors for student residency, in general, did not report the level of
Effectively Monitor or    school and student noncompliance that we observed in our review. For
Enforce Residency         the nine schools for which we could directly assess compliance,23 with few
                          exceptions, proofs of residency were missing for large portions of the
Verification Procedures
                            We could assess compliance only for those schools for which we could track the proof of residency
                          to the residency form.

                          Page 20                                              GAO/HEHS-97-161 DCPS Enrollment Count

student population. But, most DCPS Daily Activity Reports (monitoring
reports) failed to cite the missing proofs, focusing instead on students who
lived with someone other than a parent or whose forms indicated a
nonresident address or phone number. For example, in one school we
visited, we determined that about one-fourth of the students (or 108) did
not return a proof to the school. The DCPS monitoring report, however,
identified only one student living with a grandmother and two students
with nonresident addresses. In another school, we found no proofs, and
staff reported that they could not get students to provide proofs. But the
monitoring report showed that only two students had nonresident
addresses or phone numbers. Moreover, DCPS officials did not provide
monitoring reports for 3 of the 15 schools we visited, telling us that it only
prepared monitoring reports for schools where issues of nonresidency had
been identified on enrollment cards or residency verification forms. At one
of the three schools without monitoring reports, we found no proofs of
residency on file for any student.

Some of the monitors’ failure to detect and report residency problems may
have resulted from poorly specified guidance. Instructions to monitors
were not specific enough to guide implementation, for example, asking
monitors to identify students for whom parents had not “sufficiently
documented” residence. Monitoring instructions did not specify what to
examine to determine whether residency was documented or what
documentation was considered sufficient.

Furthermore, despite recommendations of previous audits, monitors had
no instructions to review the files to determine whether students had
submitted a residency form. Consequently, when monitors failed to
compare names on the student roster with those on completed residency
forms, DCPS missed a key element in determining school and student
compliance. We found forms missing for at least some of the students at 13
of the 15 schools we visited. At one school, the staff estimated that about
25 to 30 percent of the students did not return the residency forms, and, at
another school, the staff could not find about one-third of the forms.

Despite monitoring efforts and threats of sanctions, DCPS administration
did not ensure that the schools completed the residency verification
procedures. DCPS conducted no follow-up of schools failing to submit the
office copy of the residency form. In addition, on the basis of the reports
from the schools we visited, it conducted only minimal follow-up of
schools failing to collect adequate proofs. Furthermore, as noted earlier,
DCPS conducted no follow-up of those schools failing to collect residency

Page 21                                  GAO/HEHS-97-161 DCPS Enrollment Count

                              forms for all students because no one in the Central Office checked to see
                              if all forms had been received.

                              In addition, the Central Office did not consistently apply the established
                              sanctions to the students or their families for failing to submit forms or
                              proofs. As noted earlier, parents and guardians were told that failure to
                              provide proof could result in an investigation, a tuition bill, or exclusion
                              from DCPS. On the basis of our visits to 15 schools, we assessed the degree
                              of student noncompliance as very high. In one school alone, staff
                              estimated that about 80 percent of the students—or about 700 students—
                              did not comply. Yet, for all 158 schools, the Nonresident Tuition
                              Enforcement Branch reported that, as of May 1, 1997, it issued only 469
                              letters to students requesting them to submit proofs of residency,
                              collected tuition from only 35, and excluded only 156 students from DCPS
                              schools. Action was pending for another 136. DCPS officials in the
                              Nonresident Tuition Enforcement Branch told us that, at the request of
                              one of the assistant superintendents, they were focusing their enforcement
                              action mainly on high school athletes largely because the athletic program
                              may have been attracting nonresidents.

Other Districts Also Verify   Like DCPS, all the other districts reported that all new students must verify
Residency                     residency upon enrolling. Residency verification occurs either at the
                              individual schools or at central service centers. Officials in Boston and
                              Chelsea reported that the PICs verify residency. Officials in the other four
                              districts told us that all or most new students enroll and verify residency at
                              the school they will attend. School staff verify residency and check to see
                              that the student’s address falls within the attendance boundary of the
                              school. If the parent fails to provide satisfactory proof of residency, the
                              child is not allowed to enroll.

                              Other districts reported relying upon the schools to verify residency for
                              continuing students. For example, officials in Arlington, Fairfax, and
                              Prince George’s counties told us that teachers and principals are expected
                              to monitor continually for students’ possible relocation, and students must
                              provide information on address changes. Schools also often make use of
                              returned mail as a reliable data source for address changes. None of the
                              other districts we visited requires annual residency verification for all
                              students as DCPS does.

                              Page 22                                  GAO/HEHS-97-161 DCPS Enrollment Count

                        The foundation of the pupil accounting system—SIS—lacked adequate
System for Pupil        safeguards to ensure that students were accurately tracked when they
Accounting Did Not      transferred from one school to another. Furthermore, some schools did
Ensure an Accurate      not follow attendance rules, affecting later counts and projections. These
                        rules, if implemented, may have allowed some students who no longer
Count                   attended to be included in the school’s count.

SIS Process for         The student transfer process may have allowed a single student to be
Transferring Students   enrolled in at least two schools simultaneously.24 During most of the
Allowed More Than One   school year, a student’s record could be accessed and modified only by the
                        school in which the student was enrolled. When a student transferred,
School to Include a     however, the losing school was to submit the student’s record to a
Student in Its Active   computer procedure that allowed both the losing and gaining school to
Enrollment              have identical copies of the student’s record. During this process, both
                        schools could enter the student’s status as “active” or “inactive.” The
                        computer procedure provided no safeguards to ensure that the student
                        was only active at one school at a time. Until the losing school completed
                        the computer procedure with a withdrawal code, both schools could have
                        claimed the student as active or enrolled. The possible impact of this
                        vulnerability upon the count may have been sizeable. DCPS officials
                        reported that the number of transfers between schools in the District
                        during school year 1996-97 was well in excess of 20,000.

                        DCPS  officials in the MIS Branch, concerned with this problem, performed
                        periodic data runs to detect cases in which students were shown as
                        enrolled in two schools. Resolving these issues and completing the
                        transfers, however, sometimes involved a lengthy delay. We found cases
                        that took as long as 1 to 2 months to resolve. Local schools made all
                        changes—the MIS Branch did not have authority to change the data—and
                        some school staff did not use the electronic transfer procedures.
                        Furthermore, DCPS did not specify a time limit for completing the transfer.

                        In addition, students could also be counted at more than one school when
                        the massive transfers took place at year end during “roll-over”—when
                        students transferred as a group to either middle or high school. During
                        school year 1996-97, well over 6,800 roll-overs took place, and the process
                        was multistaged and generally occurred when students were still enrolled
                        in the elementary or middle schools, officials said. SIS has a programming

                          This problem is separate from the multiple record issue discussed earlier, in which two separate SIS
                        records, with different student identification numbers, were created for a single individual. In the
                        transfer process, only one record exists (in two copies)—and one identification number per student,
                        and the two copies of the record can be accessed by both schools.

                        Page 23                                                GAO/HEHS-97-161 DCPS Enrollment Count

                               anomaly allowing students to have active status in both schools’
                               databases, according to DCPS officials.

                               Sometimes students were legitimately enrolled in two schools
                               simultaneously, for example, when attending a regular high school
                               program in addition to one of the School-to-Aid-Youth (STAY)25 programs.
                               In these cases, the database of the school with the secondary program—
                               STAY—should have shown the student with the special status of “enrolled”
                               and the student’s regular school should have shown his or her status as
                               “active.” The student should have only been counted at the school where
                               active. School clerks did not use the “enrolled” code properly, however,
                               and, because the status code had no safeguards, the student could be
                               counted at both schools, according to DCPS officials.

Limitations in Capability to   During school year 1996-97, two attendance rules directly affected student
Track Attendance Could         status and therefore the number of students eligible to be counted.
Have Affected Accuracy of
                               First, schools were to reclassify as inactive, or in this case as a “no-show,”
Student Database               any student expected to enroll but not actually attending school at least
                               once during the first 10 days of school. Students classified as inactive
                               would not be included in the official enrollment count. No-shows,
                               however, were sometimes not reclassified as inactive as required by the
                               attendance rules. While most schools we visited appeared to be following
                               this rule, at least one school we visited apparently had difficulty changing
                               these students’ status to inactive. At this school, the data entry staff
                               reported that they were having trouble maintaining student status as
                               “inactive” for the no-shows. Some of these students were appearing on
                               their active rolls as late as February, possibly affecting DCPS’ official count.

                               Second, schools were required to change to inactive status those students
                               who showed up for at least 1 day but subsequently accumulated 45
                               consecutive days of absences. For students who had 45 days of absences,
                               schools reported that they only rarely changed their status to inactive.
                               School officials often told us that they did not change a student’s status
                               unless they could obtain accurate information about the student’s
                               whereabouts, confirming that the student should be dropped from the
                               rolls. School administrators stated reluctance to “give up on a student,”
                               and they viewed changing the student’s status to inactive as such. Unlike
                               the no-show rule, failing to implement the 45-day rule would not have

                                High school students are sometimes sent to a STAY program when they need to make up academic
                               deficiencies. In these cases, the STAY program focuses on the deficiencies, while the student
                               maintains enrollment for the remaining courses at his or her regular high school.

                               Page 24                                            GAO/HEHS-97-161 DCPS Enrollment Count

                            directly affected the October count. It would have affected, however,
                            subsequent counts and the accuracy of projections from them.

                            The 45-day attendance rule, if implemented, may have allowed some
                            nonattending students to be considered active and enrolled. The rule
                            enabled any student who reported 1 day to be considered enrolled until
                            evidence was obtained that he or she had transferred elsewhere or until 45
                            days had elapsed. If a student went to another school district without
                            notifying the school, the school would not have known to drop the student
                            from its rolls. Consequently, even if the student appeared only on the first
                            day of school, the 45-day time period would not have expired before the
                            official enrollment count, allowing a student to be counted who no longer
                            attended a DCPS school.

                            This 45-day time period might be considered lengthy by some other nearby
                            districts. Other school districts we visited reported that they have shorter
                            time periods. For example, Virginia law requires that students with 15 or
                            more consecutive days of absence be withdrawn from school, district
                            officials told us. Therefore, neither Arlington County nor Fairfax County
                            counts any student with 15 or more days of consecutive absence. Neither
                            does Boston count any student in this category.

                            SISprovided no safeguards to ensure that the schools followed either the
                            no-show rule or the 45-day rule. It had no feature that would allow
                            students’ status to be automatically changed to inactive on the basis of
                            absences. Nor could SIS identify students with 45 consecutive days of
                            absence—it does not readily permit calculating consecutive days of
                            absence for students throughout the school year. Consequently, quality
                            control or management assistance from the MIS Branch on this issue was
                            not possible.

Other Districts Rely on     Other districts we visited reported using essentially the same approaches
Centralized Processing or   for controlling errors in tracking student transfers as they use for
Automated Database          controlling enrollment and residency verification. For example, in Boston,
                            all student transfers take place through the PICs, where a limited number
Procedures to Control       of staff may process the transfers. The schools lack the authority or ability
Possible Errors in Pupil    to transfer students.
                            In most of the other districts, officials reported that the individual schools
                            handle student transfers. These districts rely on a variety of automatic
                            edits and procedures in their student database systems to prevent such

                            Page 25                                   GAO/HEHS-97-161 DCPS Enrollment Count

errors and serve as ongoing checks and balances on the schools. For
example, in Arlington, Fairfax, Prince George’s, and Montgomery counties,
the student database systems either do not allow a transfer to proceed
unless the losing school removes the student from its rolls or
automatically removes the student from the losing school as part of the
transfer process. The school cannot override these safeguards.

In addition, Arlington, Fairfax, and Prince George’s counties reported
using two centralized oversight mechanisms for further enhancing
accuracy in accounting for student transfers. First, they regularly and
frequently check their student databases for duplicate student entries
using students’ names and dates of birth as well as identification numbers.
These checks also help to safeguard against multiple student entries
arising from other sources such as enrollments. Arlington County
performs this check every 15 days; Fairfax County, every 2 weeks; and
Prince George’s County, daily concerning transfers.

Second, if these districts identify duplicates, they notify the school
immediately and work with the school to resolve the situation, officials
reported. For example, Prince George’s County reports duplicates from
transfers to the schools every day; when school staff log onto the
computer system in the morning, the first thing that appears is an error
screen showing duplicates from transfers as well as any other errors.
Prince George’s County officials also review these schools’ error screens
and follow up daily. If schools do not respond, according to these officials,
database management staff can readily access senior district officials to
quickly resolve such problems. In addition, in Arlington, Fairfax, and
Prince George’s counties, Boston, and Chelsea, the database staff may
make changes to the student database.

As in DCPS, all six of the districts we visited reported to us that teachers are
responsible for tracking daily attendance and schools for recording
attendance data in the student database. Most of the other districts
reported that they also use their central student databases to track all
student absences as a check on the schools’ tracking. In addition, several
districts withdraw students from school after substantially fewer days of
consecutive absences than DCPS. For example, in Boston and Arlington and
Fairfax counties, students absent 15 days in a row are withdrawn from
school. They are therefore not included in school or district enrollment
counts. These students must re-enroll if they return.

Page 26                                   GAO/HEHS-97-161 DCPS Enrollment Count

                       The District of Columbia School Reform Act of 1995 imposed enrollment
DCPS, the Board of     count reporting and audit requirements upon DCPS, the District of
Trustees, and the      Columbia Board of Education—all of the responsibilities of which have
Authority Have Not     been delegated to the Board of Trustees—and the Authority. The Reform
                       Act requires the District’s schools to report certain kinds of information.
Complied With the      The schools did not collect all the information required to be reported, and
District of Columbia   the official enrollment count that was released did not comply with the
                       Reform Act’s requirements. In addition, the Reform Act requirements to
School Reform Act      independently audit the count have not been met.

                       The Reform Act requires an enrollment count that includes—in addition to
                       data historically reported by DCPS—a report of special needs and
                       nonresident students by grade level and tuition assessed and collected.
                       The official enrollment count report released for school year 1996-97—the
                       first year of the new reporting requirements—failed to provide information
                       on special needs and nonresident students as well as on tuition assessed
                       and collected. DCPS has not provided any evidence that additional
                       documentation was released that would include the required information.
                       Despite October 1996 correspondence from the U.S. Department of
                       Education referring them to the law, DCPS officials repeatedly expressed to
                       us unfamiliarity with the law or the type of information it requires.

                       The Reform Act also stipulates that the Authority, after receiving the
                       annual report, is to provide for the conduct of an independent audit. The
                       Authority, however, had delegated this function to DCPS earlier this year,
                       according to DCPS procurement officials. With that understanding, DCPS’
                       Procurement Office, with technical assistance provided by the U.S.
                       Department of Education Inspector General’s Office,26 issued a Request
                       for Proposals (RFP). DCPS received proposals in response, and, in early
                       June 1997, the Procurement Office was preparing to make an award. When
                       we queried Authority officials at that time about their role in this effort,
                       however, they reported that they did not know of any DCPS efforts to
                       procure the audit and were preparing to advertise an RFP for the audit.
                       Subsequent correspondence from the Authority indicated that the
                       inadequacies that led to the restructuring of the public school system
                       would make auditing the count counterproductive. In addition, the
                       Authority’s comments in response to our draft report reiterated its notion

                         In response to DCPS’ request for assistance, the U.S. Department of Education Inspector General’s
                       Office reviewed DCPS’ draft RFP for an independent audit of the count. The Inspector General’s Office
                       made recommendations for improvements to the RFP, and DCPS incorporated all of them in the RFP
                       that it issued. In addition, the Department has offered to review audit plans once a contract award has
                       been made and make suggestions for revision if necessary. The U.S. Department of Education played
                       no other role in DCPS’ enrollment count process in school year 1996-97.

                       Page 27                                                GAO/HEHS-97-161 DCPS Enrollment Count

                      that auditing the flawed count would be counterproductive. In short, the
                      Reform Act’s requirements to count and report student enrollment and
                      audit that enrollment count have not been met.

                      Although DCPS has tried to respond to criticisms raised by previous audits,
Conclusions           its efforts have overlooked larger systemic issues. Consequently,
                      fundamental weaknesses remain in the enrollment count process that
                      make it vulnerable to inaccuracy and weaken its credibility. For example,
                      the lack of internal controls allows multiple records and other errors that
                      raise questions about the accuracy of the database used as a key part of
                      the count. Furthermore, unidentified nonresident students may be
                      included in the count when they avoid detection because DCPS’ sanctions
                      are not enforced.

                      An accurate and credible enrollment count demands a process with
                      stringent accountability and strong internal controls. Moreover, the need
                      to correct DCPS’ problems is more critical now than ever before. Current
                      reform initiatives have heightened public awareness of the issues and
                      increased scrutiny of the process. Meanwhile, new budget initiatives for
                      per pupil accounting will increase this level of scrutiny. Even without the
                      new initiatives, an accurate enrollment count is essential if DCPS is to
                      spend its educational dollars wisely.

                      Because the enrollment count will become the basis for funding DCPS, the
Matter for            Congress may wish to direct DCPS to report separately, in its annual
Congressional         reporting of the enrollment count, those students
                  •   fully funded from other sources, such as Head Start participants or
                      tuition-paying nonresidents;
                  •   above and below the mandatory age for compulsory public education,
                      such as prekindergarten or those aged 20 and above; and
                  •   for whom District residency cannot be confirmed.

                      We recommend that the DCPS Chief Executive Officer/Superintendent do
Recommendations       the following:

                  •   Clarify, document, and enforce the responsibilities and sanctions for
                      employees in all three areas of the enrollment count process—enrollment,
                      residency verification, and pupil accounting.

                      Page 28                                  GAO/HEHS-97-161 DCPS Enrollment Count

                  •   Clarify, document, and enforce the residency verification requirements for
                      students and their parents.
                  •   Institute internal controls in the student information database, including
                      database management practices and automatic procedures and edits to
                      control database errors.
                  •   Comply with the reporting requirements of the District of Columbia
                      School Reform Act of 1995.

                      We also recommend that the District of Columbia Financial Responsibility
                      and Management Assistance Authority comply with the auditing
                      requirements of the District of Columbia School Reform Act of 1995.

                      DCPS’ Chief Executive Officer/Superintendent stated that DCPS concurs with
Agency Comments       the major findings and recommendations of the audit and will correct the
                      identified weaknesses. He also acknowledged that the enrollment numbers
                      for school year 1996-97 are subject to question for the reasons we cited—
                      especially because the enrollment count credibility hinges almost entirely
                      on the written verification provided by local administrators. No substantial
                      checks and balances, no aggressive central monitoring, and few routine
                      reports were in place. In addition, virtually no administrative sanctions
                      were applied, indicating that the submitted reports were hardly reviewed.
                      DCPS’ comments appear in appendix III.

                      The Authority shared DCPS’ view that many findings and recommendations
                      in this report will help to correct what it characterized as a flawed student
                      enrollment process. Its comments did, however, express concerns about
                      certain aspects of our report. More specifically, the Authority was
                      concerned that our review did not discuss the effects of the Authority’s
                      overhaul of DCPS in November 1996. It also commented that our report did
                      not note that the flawed student count was one of the issues prompting the
                      Authority to change the governance structure and management of DCPS as
                      noted in its report, Children in Crisis: A Failure of the D.C. Public Schools.
                      Although we did not review the Authority’s overhaul of DCPS or the events
                      and concerns leading to that overhaul, we have revised the report to
                      clarify the Authority’s transfer of powers and responsibilities from the
                      District of Columbia Board of Education to the Emergency Board of

                      The Authority was also concerned about the clarity of our discussion of
                      the District of Columbia School Reform Act, suggesting that we enhance
                      this discussion to include the portion of the Reform Act that addresses the

                      Page 29                                  GAO/HEHS-97-161 DCPS Enrollment Count

funding of the audit. We have clarified in the report that the relevant
responsibilities of the Board of Education—including that of funding the
audit—were transferred to the Emergency Board of Trustees.

Finally, the Authority questioned statements made in our report about its
role in preparing an RFP for an audit. Specifically, it disputes our statement
that the Authority was “. . . unaware of any of DCPS’ efforts to produce the
audit and were preparing to advertise an RFP for the audit.” In disputing
our statement, the Authority asserts that this is a misrepresentation of a
conversation between a new employee of the Authority who would have
known nothing about the Authority’s contracting process and our staff. We
disagree that this misrepresents our conversations with Authority staff. In
preparing to meet with the Authority the first time, we spoke with a more
senior, long-time member of the Authority’s staff about the audit issues
who referred us to the new staff member as the expert on District
education issues. When we met with the new staff member, she stated that
she had reviewed the act and had spoken with other staff who were
preparing to develop an RFP. Furthermore, after meeting with this new
staff member, we met a second time with other Authority staff present. At
both meetings, Authority staff expressed unfamiliarity with DCPS’ efforts to
produce an audit. The Authority’s comments appear in appendix IV.

The U.S. Department of Education, in commenting on our draft report,
noted that its Office of Inspector General had no role in preparing DCPS’
enrollment count for school year 1996-97 but provided some clarifications
about correspondence between it and DCPS regarding an audit of the count.
We have revised the report where appropriate. Education’s comments
appear in appendix V.

We are sending copies of this report to the U.S. Department of Education;
the Office of the Chief Executive Officer/Superintendent, District of
Columbia Public Schools; the District of Columbia Financial
Responsibility and Management Assistance Authority; appropriate

Page 30                                  GAO/HEHS-97-161 DCPS Enrollment Count

congressional committees; and other interested parties. Please call
Carlotta Joyner, Director, Education and Employment Issues, at
(202) 512-7014 if you or your staff have any questions about this report.
Major contributors to this report are listed in appendix VI.

Sincerely yours,

Richard L. Hembra
Assistant Comptroller General

Page 31                                  GAO/HEHS-97-161 DCPS Enrollment Count

Letter                                                                                   1

Appendix I                                                                              34
                       DCPS School Sample                                               34
Scope and              Other Urban School Districts                                     35
Appendix II                                                                             36

Prior Criticisms and
Appendix III                                                                            41

Comments From
District of Columbia
Public Schools
Appendix IV                                                                             42

Comments From the
District of Columbia
Responsibility and
Assistance Authority
Appendix V                                                                              44

Comments From the
U.S. Department of

                       Page 32                        GAO/HEHS-97-161 DCPS Enrollment Count

Appendix VI                                                                                   46
                   GAO Contacts                                                               46
GAO Contacts and   Staff Acknowledgments                                                      46
Tables             Table I.1: Distribution of Schools in the Population                       34
                   Table I.2: Distribution of Schools in the Sample Selected for Site         35
                   Table I.3: Other School Districts Visited                                  35
                   Table II.1: Summary of Audits and Observations Conducted of                36
                     School Year 1994-95 and 1995-96 Official Enrollment Counts

Figure             Figure 1: DCPS Enrollment Count Process for School Year                    10


                   ADM        Average Daily Membership
                   DCPS       District of Columbia Public Schools
                   ENR        Enrolled Pupils
                   MIS        Management Information Services
                   OEA        Office of Educational Accountability
                   PIC        Parent Information Center
                   RFP        request for proposal
                   SIMS       Student Information Membership System
                   SIS        Student Information System
                   STAY       School-to-Aid-Youth

                   Page 33                                  GAO/HEHS-97-161 DCPS Enrollment Count
Appendix I

Scope and Methodology

                                            We designed our study to gather information about DCPS’ enrollment count
                                            process for school year 1996-97 and the process used by other selected
                                            urban school districts. To do so, we visited DCPS administrative offices,
                                            interviewed administration officials, and reviewed documents. We also
                                            visited randomly selected DCPS schools unannounced, interviewing school
                                            faculty and staff and reviewing student records. In addition, we
                                            interviewed officials in other urban school districts, officials in the U.S.
                                            Department of Education and the District of Columbia, and other experts
                                            in the field. We did our work between October 1996 and June 1997 in
                                            accordance with generally accepted government auditing standards.

                                            We visited 15 randomly sampled DCPS elementary and secondary schools
DCPS School Sample                          to review documents and interview faculty and staff about DCPS’
                                            enrollment count process. We selected these schools from a list of 158
                                            elementary and secondary schools provided to us by school district
                                            officials. We focused our review on regular elementary and secondary
                                            schools and excluded the two School-to-Aid-Youth (STAY) programs, two
                                            educational centers, and one elementary art center. Therefore, our final
                                            population included 153 schools. Fifteen schools were randomly selected
                                            by city quadrant (Northeast, Northwest, Southeast, and Southwest) and by
                                            level of school (elementary, middle/junior high, and senior high). Table I.1
                                            shows the population distribution, and table I.2 shows the sample
                                            distribution for schools visited.

Table I.1: Distribution of Schools in the Population
                                                        Elementary          Middle/junior        Senior high          Total
City quadrant                                              schools          high schools            schools      Number       Percent
Northeast                                                         33                      8                 6        47           31
Northwest                                                         42                      9                 10       61           40
Southeast                                                         32                      6                 2        40           26
Southwest                                                           4                     1                 0          5           3
Number                                                           111                     24                 18      153          100
Percent                                                           73                     16                 12      100
                                            Note: Percentages may not add to 100 percent due to rounding.

                                            Page 34                                            GAO/HEHS-97-161 DCPS Enrollment Count
                                               Appendix I
                                               Scope and Methodology

Table I.2: Distribution of Schools in the Sample Selected for Site Visits
                                                           Elementary           Middle/junior       Senior high                  Total
City quadrant                                                 schools           high schools           schools          Number           Percent
Northeast                                                              2                     1                    1               4          27
Northwest                                                              3                     1                    2               6          40
Southeast                                                              3                     0                    1               4          27
Southwest                                                              1                     0                    0               1           7
Number                                                                 9                     2                    4              15         100
Percent                                                              60                     13                  27           100
                                               Note: Percentages may not add to 100 percent due to rounding.

                                               We also interviewed officials in other selected urban school districts to
Other Urban School                             gather general information about their enrollment count processes. Table
Districts                                      I.3 shows the districts we visited with their enrollment count, counting
                                               method, and number of schools for school year 1996-97. We did not visit
                                               schools or interview school faculty or staff in these other districts.

Table I.3: Other School Districts Visited
                                                                                           Number of
                                                                            Enrollment        district
                                                                             count for schools during
                                                                           school year    school year          Method used to count
School district                                                                1996-97       1996-97           students
Montgomery County Public Schools, Rockville, Maryland                         122,505                 181      Enrolled Pupils
Prince George’s County Public Schools, Upper Marlboro,                        122,831                 177      Enrolled Pupils
Boston School District, Boston, Massachusetts                                  63,738                 125      Enrolled Pupils
Chelsea Public Schools, Chelsea, Massachusetts                                   5,302                  4      Enrolled Pupils
Arlington County Public Schools, Arlington, Virginia                           17,895                  30      Average Daily Membership
Fairfax County Public Schools, Fairfax, Virginia                              144,599                 232      Average Daily Membership

                                               Page 35                                            GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II

Prior Criticisms and Audits

                                                Critics have charged that DCPS’ reported enrollment numbers are
                                                overstated. Questions raised about the credibility of DCPS’ enrollment
                                                count have led to a series of reviews and audits. This appendix discusses
                                                in detail these efforts, which varied in scope and involved the efforts of
                                                several organizations. Table II.1 summarizes these efforts.

Table II.1: Summary of Audits and Observations Conducted of School Year 1994-95 and 1995-96 Official Enrollment Counts
                                                                           Audit/observation           Audits of count,
                                                                           of count, school            school
Issue                                                                      year 1994-95                year 1995-96
Enrollment issues
No documentation to support enrollment status                                  X                         X
No penalty for providing false enrollment information                                                    X
Lack of oversight or controls to ensure information in count was accurate                                X
Nonresidency issues
Poor procedures to validate residency                                          X
Procedures to validate residency not always followed                                                     X
Weak controls to detect and follow-up on nonresidency                          X                         X
Monitoring efforts failed to reconcile residency forms with rosters            Not applicable            X
Pupil accounting issues
Enrollment status incorrect                                                    X
Transfers not completed                                                        X
Duplicate records                                                              X                         X
Questions of system security and reliability                                   X                         X
Database not routinely updated to reflect current enrollment status            X                         X
No guidance for withdrawing students and excluding them from the count                                   X
Other Issue
Too much time elapsed between count and audit                                  X                         X

Grier Partnership Criticism                     In 1995, the Grier Partnership, as part of a study commissioned by DCPS,
of DCPS’ 1990 Enrollment                        asserted that results of the 1990 U.S. census suggested that the District’s
Count                                           total school-age population in 1990 might have been as much as 13,000 less
                                                than DCPS reported in its official enrollment count. Grier also expressed
                                                concern about the apparent relative stability of DCPS’ official enrollment
                                                count in the face of the District’s declining resident population.

                                                Limitations to the methodology the Grier Partnership used, however, may
                                                have caused the apparent differences to be overstated. For example, Grier
                                                did not include some subgroups—preschool (Head Start),

                                                Page 36                                 GAO/HEHS-97-161 DCPS Enrollment Count
                          Appendix II
                          Prior Criticisms and Audits

                          prekindergarten, and kindergarten students—that DCPS routinely includes
                          in its official count. Even if these groups had been included in the
                          estimates, using census data to estimate public school enrollment can be
                          problematic. For example, the Census Bureau reports that estimates
                          generated from its official files undercount some groups. From the 1990
                          census, the largest group undercounted was “renters.” Census estimates of
                          pre-primary students enrolled in school are also understated because
                          parents reporting the number of students enrolled in “regular school”
                          often fail to include their pre-primary children. Finally, declines in
                          residency do not necessarily mean declines in school enrollment. Census
                          currently projects a loss of 31,000 in the District’s population over the next
                          5 years, while projecting an increase in the number of school-aged

GAO Criticisms of DCPS’   The first of several independent audits took place following the September
October 1994 Count        29, 1994, enrollment count. At that time, DCPS organized an internal audit
                          and validation of the count. DCPS randomly selected a sample of students
                          and focused on validating these students’ actual attendance in schools
                          before the enrollment count. We were asked to observe DCPS’ internal audit

                          We questioned the reliability of the student database, finding that the
                          database used to enroll and track students—the Student Information
                          Membership System (SIMS)—included students who had not enrolled
                          before the official enrollment count. We also found that transfer students
                          were never removed from SIMS when they transferred. In addition, SIMS had
                          other errors, was not regularly updated, and had at least 340 duplicate
                          student records.

                          We also criticized DCPS’ inability to identify nonresident students and the
                          absence of procedures to validate residency. DCPS estimated that at that
                          time approximately 2 percent of its students were probably undetected
                          nonresidents. DCPS also estimated that this equaled more than $6 million in
                          lost tuition revenues.

                          We consequently recommended that DCPS periodically check SIMS for
                          duplicates and errors, particularly before the official enrollment count,
                          and update it regularly to reflect the changes in the enrollment status of
                          DCPS students. We also recommended that DCPS develop systematic

                            See District of Columbia: Weaknesses in Personnel Records and Public Schools’ Management
                          Information and Controls (GAO/T-AIMD-95-170, June 14, 1995).

                          Page 37                                             GAO/HEHS-97-161 DCPS Enrollment Count
                        Appendix II
                        Prior Criticisms and Audits

                        procedures at the school level to verify student residency and that schools
                        refer names of nonresident students to DCPS administration for
                        enforcement and collection of nonresident tuition.

Independent Auditor’s   The DCPS Superintendent, after the October 1995 enrollment count,
Findings Regarding      contracted for an independent audit and validation of the count.28 In
October 1995 Count      addition to a 100-percent validation of the count, DCPS expected that the
                        independent auditor would assess the accuracy of DCPS’ Student
                        Information System29 (SIS) and determine if school and headquarters staff
                        had followed DCPS’ policies and procedures. The independent auditor
                        chosen by DCPS conducted a full validation of the enrollment count and
                        examined SIS for duplicates and errors. The auditor failed, however, to
                        determine if DCPS school and headquarters staff consistently implemented
                        the policies and procedures developed by the DCPS administration.30

                        The independent auditor found several weaknesses in the October 1995
                        count, including problems with the way the enrollment count was taken
                        and documented by DCPS staff; lack of residency documentation and
                        validation; the questionable accuracy of SIS; and the lack of guidance for
                        withdrawing students and excluding them from the schools’ rolls. For
                        example, a new form, the Student Residency and Data Verification Form,
                        used to document residency, was piloted in some schools during school
                        year 1995-96.31 The auditor found that these forms were sent home to
                        parents but were not always returned to the schools, and the forms were
                        not reconciled to student enrollment reports to determine the number of
                        missing forms. The auditor also found 550 sets of students with the same
                        name and date of birth, that is, duplicate entries in SIS.

                        In addition, the auditor criticized the time lapse—about 4 months—from
                        the October 5, 1995, enrollment count to the audit. This meant that the
                        auditor could not validate the enrollment of some students—students who
                        were no longer in school at the time of the audit and for whom the school

                         Audit of the Official Membership of the District of Columbia Public Schools as of October 5, 1995,
                        F.S. Taylor & Associates, P.C. (Washington, D.C.: Apr. 26, 1996).
                          SIS replaced SIMS as DCPS’ automated student information database.
                          The Office of the District of Columbia Auditor, in its own review and report of the October 1995
                        enrollment count, criticized the independent auditor’s failure to evaluate the compliance of DCPS’
                        regulations and guidelines because it was an agreed-upon deliverable in the independent auditor’s
                        contract with DCPS.
                          The Student Residency and Data Verification Form piloted during the 1995-96 school year is the same
                        form used in school year 1996-97 to verify residency for all students.

                        Page 38                                                GAO/HEHS-97-161 DCPS Enrollment Count
                            Appendix II
                            Prior Criticisms and Audits

                            could provide no documentation demonstrating attendance before the

                            To remedy the problem with duplicate database entries, the auditor
                            recommended that DCPS periodically search the database for duplicates
                            and errors before the enrollment count. Because of differences found in SIS
                            and the manually prepared enrollment count report, the auditor also
                            recommended that these two data sources be reconciled periodically to
                            help update SIS.

                            Regarding timing of the audit, the auditor recommended that the audit of
                            the official enrollment count take place closer to the date of the count.
                            And, to facilitate future audits, the auditor suggested that documentation
                            exist to support a student’s attendance in school before the enrollment
                            count. The independent auditor also suggested that after an enrollment
                            count is taken, the staff responsible for monitoring attendance problems
                            have the opportunity to review the enrollment count so they can remove
                            from the count those students who have not attended at least 1 day of
                            school or who have withdrawn from DCPS.

Office of the District of   The District of Columbia Auditor, in its audit of the October 5, 1995,
Columbia Auditor Findings   enrollment count,32 found that DCPS needed significantly improved
Regarding the               procedures for student enrollment counts to ensure more reliable and
                            valid counts. The Auditor’s office expressed concerns about the security
October 1995 Count          and reliability of SIS, the absence of any penalty for providing false
                            enrollment information, and the lack of oversight or controls to ensure the
                            accuracy of the information reported on the enrollment count. In addition,
                            the Auditor found that SIS was not updated regularly to reflect changes in
                            the enrollment status of students, particularly before the official
                            enrollment count.

                            The Auditor also discussed the weak controls in place to detect
                            nonresidency and the weak procedures to collect nonresident tuition. The
                            Auditor found that DCPS did not maintain records on the number of Student
                            Residence and Data Verification Forms completed and returned by
                            students’ parents, and it did not test the information on these forms or the
                            documents provided to support the forms. As a result, the Auditor
                            reported that according to the DCPS Nonresident Tuition Enforcement

                              Review of the District of Columbia Public Schools’ Official Membership Count Procedures, Office of
                            the District of Columbia Auditor (Washington, D.C.: July 19, 1996).

                            Page 39                                               GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II
Prior Criticisms and Audits

Branch estimates, about 4,000 to 6,000 DCPS students were nonresidents
but did not pay nonresident tuition.

Consequently, the Auditor recommended that each local school
periodically reconcile SIS-generated reports with the attendance records it
maintains. This would allow for adjustments to SIS to include those
students who have physically presented themselves in class and removing
those who have not presented themselves, withdrawn, or transferred.

In addition, the Auditor suggested that unless students could document
their residency, including proof of residency, they should be excluded
from the official enrollment count. Furthermore, the Auditor suggested
that those nonresidents who pay tuition be excluded from the enrollment

Page 40                                 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix III

Comments From District of Columbia Public

               Page 41       GAO/HEHS-97-161 DCPS Enrollment Count
Appendix IV

Comments From the District of Columbia
Financial Responsibility and Management
Assistance Authority

              Page 42        GAO/HEHS-97-161 DCPS Enrollment Count
Appendix IV
Comments From the District of Columbia
Financial Responsibility and Management
Assistance Authority

Page 43                                   GAO/HEHS-97-161 DCPS Enrollment Count
Appendix V

Comments From the U.S. Department of

              Page 44       GAO/HEHS-97-161 DCPS Enrollment Count
Appendix V
Comments From the U.S. Department of

Page 45                                GAO/HEHS-97-161 DCPS Enrollment Count
Appendix VI

GAO Contacts and Staff Acknowledgments

                  D. Catherine Baltzell, Assistant Director, (202) 512-8001
GAO Contacts      Dianne Murphy Blank, Evaluator-in-Charge, (202) 512-5654

                  In addition to those named above, the following individuals made
Staff             important contributions to this report: Christine McGagh led numerous
Acknowledgments   site visits, reviewed DCPS’ enrollment count process, and cowrote portions
                  of this report; James W. Hansbury, Jr., performed numerous site visits,
                  reviewed prior audit reports, and summarized those audits. Wayne Dow,
                  Edward Tuchman, and Deborah Edwards assisted with the visits to the
                  schools; Sylvia Shanks and Robert Crystal provided legal assistance; and
                  Liz Williams and Ann McDermott assisted with report preparation.

(104870)          Page 46                                 GAO/HEHS-97-161 DCPS Enrollment Count
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order
made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address
are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office
P.O. Box 6015
Gaithersburg, MD 20884-6015

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000
or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any
list from the past 30 days, please call (202) 512-6000 using a
touchtone phone. A recorded menu will provide information on
how to obtain these lists.

For information on how to access GAO reports on the INTERNET,
send an e-mail message with "info" in the body to:


or visit GAO’s World Wide Web Home Page at:


United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                 Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested