District of Columbia Public Schools: School Year 1996-97 Enrollment Count Vulnerable to Errors

Published by the Government Accountability Office on 1997-11-20.

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

                              United States General Accounting Office

GAO                           Testimony
                              Before the Council of the District of Columbia, Committee
                              on Education, Libraries, and Recreation

For Release on Delivery
Expected at 11:00 a.m.
Thursday, November 20, 1997
                              DISTRICT OF COLUMBIA
                              PUBLIC SCHOOLS

                              School Year 1996-97
                              Enrollment Count
                              Vulnerable to Errors
                              Statement of Cornelia M. Blanchette, Associate Director
                              Education and Employment Issues
                              Health, Education, and Human Services Division

District of Columbia Public Schools: School
Year 1996-97 Enrollment Count Vulnerable
to Errors
               Mr. Chairman and Members of the Committee:

               I am pleased to be here today to assist the Committee in its oversight of
               the District of Columbia Public Schools’ (DCPS) enrollment count. An
               accurate count of the number of enrolled students is the cornerstone of a
               school district’s financial needs assessment. Although in the past DCPS has
               not received 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 for DCPS’ district- and school-level planning,
               staffing, funding, and resource allocation.

               Today I will discuss our recent report1 on the enrollment count process
               that DCPS used in school year 1996-97. Our report was prepared at the
               request of the House Committee on Government Reform and Oversight’s
               Subcommittee on the District of Columbia. The Subcommittee’s request
               was in response to criticisms raised over the past several years about the
               accuracy of DCPS’ enrollment count. Specifically, the Subcommittee asked
               us to examine DCPS’ enrollment count process to determine whether the
               process appeared sufficient to produce an accurate count.

               The information I am presenting today is based on interviews with and
               documents obtained from DCPS administrative staff, city officials, officials
               in other urban school districts and their state departments of education,
               officials in the U.S. Department of Education, and education experts. We
               also visited 15 DCPS elementary and secondary schools, randomly selected
               by school level and city quadrant. During our school visits, we interviewed
               principals, school administrative staff, and teachers and reviewed selected
               documents. It is important to note that we have done no work involving
               DCPS’ enrollment count process since issuing our report and therefore can
               report nothing about the process DCPS used for its school year 1997-98
               enrollment count. Our comments today pertain only to the process that
               was used for the school year 1996-97 count.

               In summary, even though DCPS changed parts of its enrollment process in
               school year 1996-97 to address prior criticisms, the process remained
               flawed. Some of the 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

                District of Columbia Public Schools: Student Enrollment Count Remains Vulnerable to Errors
               (GAO/HEHS-97-161, Aug. 21, 1997).

               Page 1                                                                        GAO/T-HEHS-98-53
District of Columbia Public Schools: School
Year 1996-97 Enrollment Count Vulnerable
to Errors

(SIS), but DCPS had only limited mechanisms for correcting these errors.
For example, although Management Information Services personnel
maintained SIS, they had no authority to correct errors. Furthermore, DCPS’
practice of allowing principals to enroll unlimited out-of-boundary
students increased the possibility of multiple enrollment records for one

In addition, DCPS’ official enrollment count included categories of students
usually excluded from enrollment counts in other districts when the
counts are used for funding purposes. For example, DCPS included in its
enrollment 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 of Columbia, including Head Start
participants,2 prekindergarten students (age 4), preschool students (age 0
to 3), and some senior high and special education students aged 20 and
older.3 In contrast, the three states that we visited reported that they
exclude from enrollment counts used for funding purposes any student
who is above or below mandatory school age or who is fully funded from
other sources. 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

Problems also persisted in the critical area of residency verification. In
school year 1996-97, schools did not always verify student residency as
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. Furthermore, schools
did not always follow attendance rules, and SIS lacked the capability to
track implementation of the rules. Finally, some attendance rules, if
implemented, could have allowed counting of nonattending students.

 Head Start has its own funding source.
 The District of Columbia School Reform Act of 1995 requires separate reporting of some of these
groups but does not require that they be included in aggregate counts.

Page 2                                                                          GAO/T-HEHS-98-53
    District of Columbia Public Schools: School
    Year 1996-97 Enrollment Count Vulnerable
    to Errors

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

    Finally, the District of Columbia School Reform Act of 1995 imposed
    enrollment count reporting and audit requirements. The act requires the
    enrollment count process to produce an enrollment count that includes
    the number of special needs and nonresident students by grade level and
    the amount of tuition assessed and collected. The official enrollment count
    report released for school year 1996-97 did not provide this information.
    The act also requires the District of Columbia Financial Responsibility and
    Management Assistance Authority (Authority) to provide for an
    independent audit of the enrollment count. The Authority decided,
    however, that the inadequacies that led to the restructuring of the public
    school system would make auditing the school year 1996-97 count
    counterproductive. In short, the Reform Act’s audit requirement was not

    Because the enrollment count will become the basis for funding DCPS, we
    recommended in our report that the Congress consider directing DCPS to
    report separately in its annual reporting of the enrollment count those

•   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 those in prekindergarten or those aged 20 and above; and
•   for whom District residency cannot be confirmed.

    We also recommended that the DCPS Chief Executive Officer/
    Superintendent do the following:

•   Clarify, document, and enforce the responsibilities and sanctions for
    employees involved in the enrollment count process.
•   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.

    Page 3                                                      GAO/T-HEHS-98-53
    District of Columbia Public Schools: School
    Year 1996-97 Enrollment Count Vulnerable
    to Errors

•   Comply with the reporting requirements of the District of Columbia
    School Reform Act of 1995.

    We further recommended 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

    In commenting on a draft of our report, DCPS’ Chief Executive Officer/
    Superintendent stated that DCPS concurred with our major findings and
    recommendations and would 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 hinged almost entirely on the written
    verification provided by local administrators. He said that no substantial
    checks and balances, no aggressive central monitoring, and few routine
    reports were in place. In addition, he said that virtually no administrative
    sanctions were applied, indicating that the submitted reports were hardly

    The Authority shared DCPS’ view that many findings and recommendations
    in our report will help to correct what it characterized as a flawed student
    enrollment count process. Its comments did, however, express concerns
    about certain aspects of our report. The Authority was concerned that we
    did not discuss the effects of the Authority’s overhaul of DCPS in November
    1996.4 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. In the report, we explained
    that we did not review the Authority’s overhaul of DCPS or the events and
    concerns leading to the overhaul.

    Other comments on our report by the Authority and the U.S. Department
    of Education dealt with technical suggestions. The complete comments of
    DCPS’ Chief Executive Office/Superintendent, the Authority, and the
    Department of Education, along with our responses to the comments, are
    included in our report.

     For many years, DCPS had been governed by an elected Board of Education. In November 1996, the
    specially appointed 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. The Authority also replaced DCPS’
    superintendent with a Chief Executive Officer/ Superintendent.

    Page 4                                                                      GAO/T-HEHS-98-53
           District of Columbia Public Schools: School
           Year 1996-97 Enrollment Count Vulnerable
           to Errors

           Mr. Chairman, this concludes my prepared statement. I would be pleased
           to respond to any questions you or members of the Committee may have.

(104913)   Page 5                                                  GAO/T-HEHS-98-53
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