Irving ISD Discipline Audits

KIMBERLYEE CHAPPELL, CIA, CGAP DR. NEIL DUGGER Internal Auditor Interim Superintendent of Schools

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AUDIT OF DISCRETIONARY DISCIPLINARY ALTERNATIVE EDUCATION PLACEMENT (DAEP) AUGUST 11, 2009 BACKGROUND In 1995, the 74th Texas Legislature enacted the Safe Schools Act designed to make Texas public school safe from violent and disruptive students. It created Disciplinary Alternative Education Programs (DAEPs) and Juvenile Justice Alternative Education Programs (JJAEPs) so that students who were disruptive, suspended, or expelled could continue their education away from regular classroom settings. To evaluate districts’ use of DAEPs and JJAEPs, the Disciplinary Action Data – Student (425 Record) was added to the Public Education Information

anagement System (PEIMS) to obtain the data necessary for analyzing these dataM

1.

In 2007, the state began distinguishing school districts whose discretionary DAEP placement rate (percentage) exceeded that state’s placement rate. This analysis examined the percentage of all students placed in DAEP at the district’s discretion; as well as the African American and economically disadvantaged (2007 only) groups. According to the discipline data reported for the 2007 and 2008 school years, Irving ISD’s discretionary placement rate has exceeded the state’s rate for all groups examined. The following table depicts the district’s rating and provides a comparison with the state.

2008 2007 District Rate State Rate District Rate State Rate All Students 2.7 1.7 2.9 1.9 African American 5.0 3.4 4.9 3.4 Economically Disadvantaged No Information 2.1 1.8 Difference Score 2.3 1.7 2.0 1.5

In summary, the district reported that 2.7% of its student population (5% of the African American population) were removed from the traditional classroom setting and placed in the District’s off-campus alternative education programs (i.e. Wheeler Transitional and Development and Secondary Reassignment Centers) during the 2008 school year.

Roles and Responsibilities of 425 Coordinators To aid in the management of the district’s disciplinary data, the 425 coordinator’s position was created by central administration. The position was created to oversee the disciplinary records of the campus. Principals were asked to assign an administrator for their campus, who would be responsible for:

• Attending training (provided by central administration) on updates, and distributing the information to their campuses,

• Reviewing the COGNOS reports for any discrepancies, • Ensuring the integrity of the data input into Student Plus, and • Addressing any PEIMS errors found during submissions.

1 2008 Discipline Data Validation Manual

Throughout the school year, central administration forwards COGNOS reports to the 425 coordinators which summarize all incidents input into Student Plus by the campus. In addition, four error reports are also forwarded to the 425 coordinator. These reports should be reviewed and corrected to ensure that data submitted to the TEA is accurate.

OBJECTIVES, SCOPE AND METHODOLOGY The intent of the audit is to examine the disciplinary records, and ultimately:

• Obtain an understanding of the district’s high discretionary placement rate of its African American student population; and

• Determine whether disciplinary actions are equitably administered to the District’s ethnically diverse student population.

To achieve these objectives, Internal Audit (IA) reviewed the 425 records for all campuses (through March 31, 2009). The data from these records were used in determining the district’s discretionary placement rate for the 2009 school year (using enrollment as of the 1/9/2009 snapshot date). The formula used by the state in calculating the Discretionary DAEP Placement

ate is a follows: R

Discretionary number of discretionary DAEP placements of students for the school year (all students or African American students)

District number of students (all or African American) in attendance in school year

Discretionary Placement Rate (all students or

African American students)=

This formula only takes into account students removed from the campus and placed in the district’s off campus alternative education programs. In addition, it only includes those incidents in which the campus administrators have the discretion to determine the disciplinary action taken against the student. During Internal Audit’s testing, this formula was applied to all ethnic groups, to determine whether any other ethnic group’s placement rate exceeded the district’s overall rate and the state’s rate (from prior school years). In addition, the following testing of disciplinary data was performed:

• Calculation of discretionary DAEP placement for each campus, • Analyses of ethnic group placement for all disciplinary actions (i.e. In-School Suspension,

Out-of-School Suspension, etc.), • Brief analyses of the integrity of disciplinary data records, and • Comparison of the average number of days ethnic groups are removed from the classroom

setting.

Scope Limitations At the initiation of audit test work, it was noticed that the discipline data was incomplete (i.e. one campus had not reported any data for the entire school year as of March 2009). Although the 425 coordinators were informed of the impending audit, and were given multiple opportunities to review (and correct) data input into Student Plus, Internal Audit’s review revealed numerous errors. Due to the time constraints, the campus with the largest number of questionable items was contacted. Although some of these issued were corrected by resubmission, complete reliance can not be placed on the data submitted to PEIMS.

OVERALL CONCLUSION Based on the test work performed Internal Audit has concluded that insufficient monitoring is being performed at the campus level to ensure the integrity of the data submitted to the state to

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calculate the district’s placement rate (for both the overall district and the African American group). Numerous errors were discovered in the data reported for the 2009 school year, which should have been detected during the reviews performed by the campus’ 425 coordinator. In addition, it appears processes are not sufficient at the campus level to ensure that errors (i.e. duplications) will not occur. Lastly, the Student Plus system is not designed with controls to nsure that data input by the campuses is logical. e

In regards to analysis of IISD’s discretionary DAEP placement rates, IA’s calculation is consistent with the previous school years. It appears that 2009 African American discretionary placement rate (5.1) will exceed the district’s placement rate for all students (2.7). The additional testing performed on the remaining ethnic groups further reveals the African American is the only ethnic group whose placement rate exceeds the district’s overall placement rate.

RECOMMENDATION It is recommended that the disciplinary process become standardized throughout the district. Although it is customary for campuses to design the processes for documenting disciplinary actions, it appears that this current method does not ensure the integrity of the data reported in PEIMS. In addition, it appears that the integrity of our attendance data is also impacted, which if tested during the TEA visit, could result in possible assessments against the district’s state funding.2

Central and campus administration should coordinate their efforts to improve the district’s data quality. Possible actions could include the following:

• Create standardized procedures for the 425 coordinators, which will provide guidance on performing their duties, and ensure consistency in the process.

• Standardize the documentation required for disciplinary data. This could include consolidating the district’s safeguard form with campus forms.

• Implement deadlines for updating the disciplinary records and submitting corrections for the reports sent to the 425 coordinators.

• Require all 425 coordinators and the data entry clerks to attend the required training. • Require more specific incident information to be input into the system. • Incorporate the responsibilities of the discipline administrators into their annual evaluations. • Obtain a database which will perform data validation and reasonableness checks. The

current system allows erroneous, incomplete or invalid information to be input. For example, incident dates and actions dates could be any date (i.e. dated entered from 2006/2007 school year, or any day (Saturday, Sunday, or holiday), or be left blank in the database.)

MANAGEMENT’S RESPONSE Central and campus administration will coordinate their efforts to address the recommended actions presented in the discipline internal audit:

• Establish a task force of twelve (12) campus discipline 425 Coordinators to hear the audit report and draft a plan of action to address the issues presented in the discipline audit. The Task Force will meet on August 10, 8-10:00 A.M., Board Conference Room; August 12, 1-3:00 P.M., TR 3; and if needed, August 14, 8-10:00 A.M., TR 1. A discipline handbook will be developed to include standard procedures and forms that will ensure consistency in the process and data integrity.

2 TEC, §42.255, 19 TAC §129.21(m)

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• Present findings of the discipline audit to all principals at the general principals’ meeting on September 1.

• Conduct discipline accounting training for all discipline administrators on September 10, 15, and 17.

• Monitor the progress of the plan every six weeks throughout the school year. As designed by the task force.

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OBSERVATIONS

Review of Discretionary Alternative Education Placement (DAEP) Internal Audit reviewed the 2009 disciplinary data to determine whether the trend, identified by the state, continued for the current school year. Using the 1/9/2009 enrollment snapshot, the placement rates for the district, as well as the placement rates for all ethnic groups, were calculated. For disciplinary data reported as of 3/31/09 the African American discretionary DAEP placement has again exceeded the district’s rate. In fact, the African American group is the only ethnic group whose placement rate exceeded the district’s rate. The placement rate for the overall district was 2.7 (excluding early childhood campuses). This rate exceeds the 2007 and 2008 state rate for all students (1.9 and 1.7 respectively), and is consistent with IISD’s rates for the same years (2.9 and 2.7 respectively).

American Indian Asian African

American Hispanic Caucasian

District Rate 2.7 Placement Rate 1.1 0.5 5.1 2.4 2.3 Difference Score (1.6) (2.2) 2.4 (0.2) (0.4)

Comparison of Discretionary Placement by Ethnic Group Population The following chart depicts the disciplinary actions assigned to the different ethnic groups, as compared to the ethnic makeup of the entire student population. As shown, when compared to their representation of the population, African American students are significantly overrepresented in all types of placements.

68%

15%

13%

4%

57%

12%

29%

2%

62%

13%

23%

1%

58%

15%

26%

1%

62%

13%

24%

1%

0%0%

100%

0%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

All Students(31,072)

Expel/JJAEP(42)

ISS (8,625) OSS (2,083) AEP (824) SpEd AEP (3)

AsianAfrican AmericanCaucasianHispanic

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Comparison of DAEP Placement Rates All Campuses Testing was further extended to identify those campuses with placement rates that exceeded the district or comparable campuses. The results are summarized below.

• All Campuses/All Ethnic Groups For the 34 campuses tested (early childhood were excluded), twenty-nine percent of the campuses’ DAEP placement rates exceeded the district’s rate of 2.7. All ten were secondary campuses.

• Secondary Campuses/All Ethnic Groups The placement rate for the 13 secondary campuses was 4.8. Six of the 13 (46%) campuses exceeded this rate.

• Elementary Campuses The placement rate for the 21 elementary campuses was 0.4. Five of the 21 (24%) campuses exceeded this rate.

Comparison of Ethnic Group Placement Rates The placement rates were calculated for the individual campuses/clusters, and compared to the placement rate for each ethnic group for that campus/cluster. The results are summarized in the following tables. This testing proves that over one-half of the campuses’ placement rates exceed the campus’ rate of DAEP placement for African American students. However, the campus with the largest difference between rates is Irving High. Incidentally, this campus represented approximately 50% of the errors found during IA’s cursory review (see Data Integrity section below.)

• Secondary Ethnic Group Comparison The placement rate for each campus was calculated and compared against the ethnic group placement rate for the same campus. The percentage of discretionary DAEP placement for African American students was more than double the placement of the Hispanic and Caucasian groups at the secondary campuses.



# of campuses whose placement rate exceeded the overall secondary DAEP placement rate

0 0 10 3 5

% of secondary campuses 0% 0% 77% 23% 38%

• Elementary Ethnic Group Comparison The placement rate for each campus was calculated and compared against the ethnic group placement rate for the same campus. The discretionary DAEP placement of African American students exceeded the overall placement for elementary campuses for 52% of the campuses.



# of campuses whose placement rate exceeded the overall elementary DAEP placement rate

1 1 11 1 7

% of elementary campuses 5% 5% 52% 5% 33%

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• Cluster Comparison of placement rates between clusters reveals that the African American placement rate in the Central cluster (6.7) exceeded the overall placement rate for all African American students (5.1); and the placement rate for the other two clusters. This rate seems high when African American students represent only 11% of the Central cluster’s population (compared to 23% of the North cluster).

In addition, the placement rate for African Americans exceeded the district’s overall rate (2.7) for all three clusters and the Academy of Irving ISD.



Placement Rate 0.0 1.0 6.7 2.4 2.1 Central (Irving) % of Population 0% 3% 11% 73% 13% Placement Rate 0.0 0.3 4.9 2.5 2.4 North (MacArthur) % of Population 0% 6% 23% 50% 20% Placement Rate 3.1 0.3 4.3 2.5 2.3 South (Nimitz) % of Population 0% 4% 8% 66% 21% Placement Rate 0.0 0.0 5.0 2.2 12.0 Academy of Irving

ISD % of Population 0% 7% 8% 70% 15% Placement Rate 0.0 0.9 0.8 1.3 1.4 Union Bower

Center % of Population 0% 0% 9% 80% 11%

Comparison of Length of DAEP placement by Ethnic Group To determine whether equitable treatment was applied across ethnic groups when students were removed from the instructional setting, Internal Audit compared the number of days a student was removed from the classroom for each incident codes. In addition, this testing was applied to hose students who had multiple offenses (two and three incidents). (Refer to Attachment A) t

As depicted in the attached tables, for the three largest ethnic groups (African American, Hispanic and Caucasian), the deviation was not greater than .5 days for those students with one or two incidents. However, for students with three incidents, African American students xceeded the Hispanic group by 1.6 days and the Caucasian group by 3.1 days. e

Overall, the Hispanic students incurred the greatest average number of days per incident(s), when compared against comparable incidents for the African American and Caucasian students.

Removal from the Instructional Setting Internal Audit compared the removal of students from the instructional setting (out of school suspension). Based on the comparison, on the average Caucasian and Hispanic students were removed from the instructional setting more than the other ethnic groups.



Days of Out of School Suspension 8.0 65.0 1,642.5 3,324.5 954.5 Number of incidents 8 34 910 1,627 466 Average Day(s) per Incident 1 1.9 1.8 2.04 2.05

Data Integrity Internal Audit tested the reasonableness and reliability of the data entered into Student Plus (which is ultimately reported to the TEA) and the attendance data recorded for the disciplinary

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actions taken during the school year. The purpose of these tests was to test the accuracy of the data recorded in Student Plus, and ultimately reported to the TEA.

Reliance can not be placed on the Discipline Data Upon scanning the discipline records for the district (Excel format), the auditor found numerous discrepancies. It should be noted that these discrepancies were found reviewing an EXCEL spreadsheet provided by the PEIMS Department.

• A single incident was entered more than once into Student Plus, under different incident number. Therefore, the number of incidents reported to the state was increased.

• Incident dates and action dates were erroneous entered in the system. Campuses recorded incidents as occurring on the weekend, or on student holidays.

• Actions against students were entered into the discipline database more than once (under a single incident).

Disciplinary Actions are not supported by Student Attendance Data Attendance data in the Student Plus system did not accurately reflect the disciplinary actions recorded on the 425 records. Disciplinary action for 154 students (8 secondary campuses) was compared against the attendance recorded in Student Plus. Attendance for 55 actions (36%) did not agree to disciplinary action assigned by the campus. The following errors were encountered:

• Disciplinary action reported in the attendance database could not be traced to an incident in the discipline database.

• Students’ attendance in Student Plus did not reflect the removal from the classroom (ISS, OSS)

• Funded absences were recorded as non-funded absences (i.e. ISS placements recorded as unexcused absences).

• The dates the students were assigned to DAEP did not agree with the days students were marked absent from the classroom.

• The supporting documentation for the disciplinary action did not agree to the data input into Student Plus for incident dates and action start dates.

• A student was marked absent (ill) for all courses on the incident date.

Auditor’s Note: IA review of the records was not an in-depth review. Excel tools were used to test the reasonableness of the data. More intensive review will be required of the campuses to determine the extent of inaccuracies reported in 425 records.

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REPORT DISTRIBUTION

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Lane Ladewig Division Director Campus Operations Dr. Alice Owen Executive Director of Technology Dr. Abby Melton Program Director - PEIMS Dr. Neil Dugger Interim Superintendent of Schools

ATTACHMENT A

Students with One Incident American Indian Asian African American Hispanic Caucasian

Incident # of Days

# of Students Average # of

Days # of

Students Average # of Days

# of Students Average # of

Days # of

Students Average # of Days

# of Students Average

01 0.0 0 - 0.0 0 - 3.0 3 1.0 6.0 5 1.2 0.0 0 - 20 0.0 0 - 0.0 0 - 340.0 9 37.8 304.0 6 50.7 88.0 2 44.0 21 9.0 5 1.8 186.5 60 3.1 1,162.5 475 2.4 3,952.0 1497 2.6 960.0 360 2.7 22 0.0 0 - 0.0 0 - 0.0 0 - 0.0 0 - 3.0 1 3.0 33 0.0 0 - 0.0 0 - 0.0 0 - 0.0 0 - 3.0 1 3.0 41 0.0 0 - 5.0 2 2.5 179.0 16 11.2 765.0 56 13.7 104.0 12 8.7 50 0.0 0 - 0.0 0 - 0.0 0 - 91.0 8 11.4 38.0 3 12.7

Overall Average 1.8 3.1 3.3 3.3 3.2

Students with Two Incidents

American Indian Asian African American Hispanic Caucasian

Incident # of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

01 01 0.0 0 - 0.0 0 - 2.0 1 2.0 0.0 0 - 0.0 0 - 01 21 0.0 0 - 0.0 0 - 4.0 2 2.0 41.0 7 5.9 0.0 0 - 10 21 0.0 0 - 0.0 0 - 0.0 0 - 4.0 1 4.0 0.0 0 - 20 20 0.0 0 - 0.0 0 - 0.0 0 - 50.0 1 50.0 0.0 0 - 20 21 0.0 0 - 0.0 0 - 0.0 0 - 317.0 7 45.3 8.0 1 8.0 20 50 0.0 0 - 0.0 0 - 22.0 1 22.0 0.0 0 - 0.0 0 - 21 21 59.0 3 19.7 61.0 13 4.7 1,023.0 200 5.1 2,520.3 496 5.1 650.0 115 5.7 21 22 0.0 0 - 0.0 0 - 22.0 1 22.0 0.0 0 - 0.0 0 - 21 33 0.0 0 - 0.0 0 - 0.0 0 - 21.0 1 21.0 0.0 0 - 21 41 0.0 0 - 0.0 0 - 178.0 10 17.8 308.0 18 17.1 67.0 9 7.4 21 50 0.0 0 - 0.0 0 - 0.0 0 - 91.0 2 45.5 29.0 1 29.0 41 41 0.0 0 - 56.0 1 56.0 0.0 0 - 0.0 0 - 23.0 1 23.0 Overall Average 19.7 8.4 5.8 6.3 6.1

ATTACHMENT A

Students with Three Incidents American Indian Asian African American Hispanic Caucasian

Incident # of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

# of Days

# of Students

Average Days

01 21 21 0.0 0 - 0.0 0 - 32.0 1 32.0 6.0 1 6.0 0.0 0 - 10 21 21 0.0 0 - 0.0 0 - 0.0 0 - 5.0 1 5.0 0.0 0 - 20 20 20 0.0 0 - 0.0 0 - 59.0 1 59.0 0.0 0 - 0.0 0 - 20 20 21 0.0 0 - 0.0 0 - 0.0 0 - 83.0 1 83.0 0.0 0 - 20 21 21 0.0 0 - 8.0 1 8.0 315.0 4 78.8 313.0 6 52.2 93.0 1 93.0

21 21 21 23.0 4 5.8 48.0 7 6.9 827.0 95 8.7 2,613.

5 291 9.0 629.5 76 8.3 21 21 41 0.0 0 - 0.0 0 - 149.0 6 24.8 461.0 16 28.8 20.0 1 20.0 21 21 50 0.0 0 - 0 0 - 0.0 0 - 61.0 2 30.5 28.0 1 28.0 21 41 41 0.0 0 - 0 0 - 0.0 0 - 67.0 2 33.5 0.0 0 -

Overall Average 5.8 7.0 12.9 11.3 9.8

KIMBERLYEE CHAPPELL, CIA, CGAP DR. NEIL DUGGER Internal Auditor Interim Superintendent of Schools

Discretionary DAEP Placements Audit Follow-Up

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Audit Follow-Up Report Discretionary DAEP Placements

May 12, 2010

“The District has made a concerted effort to address the disproportionate rate of African Americans assigned to alternative education for discretionary incidents; however data integrity continues to be a

risk.” Executive Summary At the request of the Finance Committee of the Board of Trustees, the discretionary disciplinary alternative education placements were examined for the first semester of the 2009/2010 school year. It appears that the actions taken by Irving ISD to address the high placement of African American students have been effective. However, the District has not fully addressed its data integrity issues. Internal Audit found high error percentages in the attendance and disciplinary data reported in the student information system.

Background In August 2009, Internal Audit issued the audit report Audit of Discretionary Disciplinary Alternative Education Program (DAEP) Placements. The objectives of the audit were 1) to obtain an understanding of Irving ISD’s (the District’s) high discretionary placement rate of its African American student population, and 2) to determine whether disciplinary actions were equitably administered to the District’s ethnically diverse student population. The audit found that the placement rate for African American students not only exceeded the District’s placement rate for the same period, but it was the only ethnic group that exceeded the District’s rate. In addition, the audit found insufficient monitoring was being performed at

the campus level to ensure the integrity of the disciplinary and attendance data submitted to the State. Management was in general agreement with the report and agreed to implement corrective actions to address the Internal Audit’s findings.

Scope and Methodology The objective of this follow-up review was to determine how the District had progressed in implementing corrective actions. The placement rates for the District and all ethnic groups were calculated using the disciplinary data for the first semester of 2009/2010 school year. Interviews and meetings were held with central and campus administration regarding the current procedures. Supporting documentation was reviewed to verify the accuracy and integrity of the data reported to the PEIMS department, and ultimately the State. Furthermore, the scope of this follow-up audit was expanded to examine whether any individual’s referral of African American students appeared excessive or questionable. Based on the data recorded in the student information system, Internal Audit scrutinized whether any teacher’s removal of African American students could be deemed biased or racially motivated.

This audit was conducted in accordance the Institute of Internal Auditor’s International Professional Practices Framework.

Accomplishments Since the issuance of the audit report, it appears that the District has made a concerted effort to address the disproportionate rate of African Americans assigned to alternative education for discretionary incidents. In fact, it appears that all disciplinary placements for African American students have decreased from the 08/09 to 09/10 school years (first semester data compared for both periods).

African American Discretionary Placements (1st Semester)

08/09 09/10Percentage

Chage

Expulsions/JJAEP 6 1 -83%ISS 1280 924 -28%OSS 331 227 -31%DAEP 124 67 -46%

Although the African American group is still overrepresented in discretionary placements for in school suspension, out of school suspension and discretionary alternative education placements, the gap between its representation in placements type and population has decreased from 6% -10% to (3%) – 6%.

68%

14%

13%

4%

70%

10%

10%

10%

65%

14%

19%

1%

65%

16%

17%

2%

67%

16%

16%

2%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

All Students (31,864)

Expel/JJAEP (10) ISS (4,851) OSS (1,309) DAEP (423)

09/10 Discretionary Placement of Students by Ethnic Group

1st Semester Only

American Indian

Asian

African American

Caucasian

Hispanic

See Attachment A for larger view

DAEP Rate Calculation The discretionary placement rates for the District and the three largest ethnic groups

decreased between the 08/09 and 09/10 school years. The African American placement rate still exceeded the District’s rate, however, the difference between the two periods decreased immensely.

Comparison of DAEP Rates 08/09 09/10 Difference

District 2.7 1.3American Indian 1.1 0.0Asian 0.5 0.6 0.1African American 5.1 1.6Hispanic 2.4 1.3Caucasian 2.3 1.4

(1.4)(1.1)

(3.5)(1.1)(0.9)

Factors Contributing to the Decreased Placements According to management, several factors have contributed to the dramatic decrease in discretionary placements. Internal Audit believes that these factors, and the actions taken by central administration, brought about a district-wide awareness and change in the handling of not only African American students, but to the entire student body. Passage of HB 171 House Bill 171 required that consideration be given to mitigating factors in determining the disciplinary action taken against a student. Instead of having a zero tolerance policy, districts should consider such factors as self-defense, intent, disciplinary history, or a disability, before suspending, expelling or removing a student to an alternative education program. Emphasis of a “Positive Proactive Approach to Discipline” The District stressed the value of keeping the student in the classroom. Best practices were shared among campus administrators in administering disciplinary actions other than removing the student from the instructional setting. Based on interviews with campus administrators, more are assigning students to Friday after-school detention or Saturday School.


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Tone at the Top – Resolution No. 09-10-08 The Board of Trustees adopted Resolution No. 09-10-08 in November 2009, which implemented strategies to “eliminate any disproportionate imposition of discipline or assignment to alternative educational programs due to or resulting from the student’s race, color, national origin, by the end of the 2010-2011 School Year”. African American Discretionary Referrals There were 1,072 discretionary referrals for African American students which resulted in the student being removed from the instructional setting. According to the student information system, 60% of the referrals were made by teachers (including substitutes) and paraprofessionals. The remaining 40% were made by campus administrators, police officers, and campus auxiliary officers. On the average, however, there were 1.85 referrals for every teacher/paraprofessional, but 7.7 referrals for every campus administrator, police officer or campus auxiliary officer. Assuming the data recorded in the student information system is accurate, campus administrators (not teachers) are initiating the disciplinary actions which have resulted in African American students being removed from the instructional setting. Further examination of the referrals made by teachers also revealed that those teachers with the highest number of referrals resulted from repeat offenders. For example, the teacher with the highest African American referrals resulted for one student being referred thirteen times. In fact, those teachers with the most referrals resulted from one to three students being referred more than once. The most students referred by one teacher were five elementary students which resulted in seven referrals.

Significant Remaining Risks Actions are still needed to improve the integrity of disciplinary and attendance data reported by the campuses. It appears that the efforts made

by central administration (i.e. additional training and labs and the standardization of the discipline form) have not fully addressed the issues resulting in poor data quality. (Refer to Attachment B) Disciplinary Data Internal Audit examined seventy-two percent of the discipline records (315 out of 435): Erroneous data was found in seventy-five

percent (72%) of the records reviewed. Three percent (3%) of the records were

duplications or errors. A review of a report created by the Reassignment Center (RAC) revealed that 13 students were placed in AEP, but disciplinary records were not created for the students by the home campuses. Attendance Data In addition, attendance errors were noted during the review. Attendance was reviewed for 225 incidents. Errors were noted for 48% of the incidents.

The errors included both an underreporting and over-reporting of Average Daily Attendance (ADA).

Numerous teachers were not reporting attendance on a daily basis (i.e. students assigned to RAC were not marked absent by the teacher).

Some attendance clerks misunderstood the District’s procedures for students assigned to AEP, or failed to update the attendance for students assigned to AEP.

Inadequate Follow-Up for Carryover Students Approximately 30 of the erroneous 425 Records resulted from the home campus’ failure to follow up on students who did not complete their AEP placement from the prior school year. Campuses have the option to require a student who does not serve all days assigned to AEP, to report the following school year.


Page 3 of 4

Additional Recommendations In addition to recommendations made in the original report, Internal Audit also recommends the following.

1. Assigning the responsibility of updating to RAC Based on interviews with campus personnel, once the student has been assigned to the RAC, the home campus is not aware of the student’s activity. For example, numerous errors existed because the student failed to report to RAC on the day originally assigned.

Since the RAC is aware of all activity once the student has reported to the campus, this should increase the integrity of the data entered for discipline and attendance.

2. Creating an additional attendance clerk position for the RAC The process for recording attendance at the RAC differs from traditional campuses. The teacher manually records the attendance for his/her classroom, which is given to the attendance clerk to manually record on an attendance log for the twelve secondary campuses. The attendance clerk updates any absences in the student information system. The home campus is responsible for updating the system to denote the student is present at the RAC.

To streamline into a more efficient process, Internal Audit recommends hiring another attendance clerk, who could assist the current attendance clerk in recording all attendance for the RAC, and also assist in updating the disciplinary data.

3. Discontinuing or minimizing the practice of overlapping discretionary AEP across school years Since numerous errors resulted from those students whose placements overlapped school years, Internal Audit recommends minimizing this practice to those students

with mandatory placements, or those considered unsafe to return to the campus.

4. Providing a more effective communication channel between the home campus and RAC The communication channels between the RAC and the secondary campuses have not been optimized to ensure that student data is accurately updated and reported. Internal Audit recommends that District administration coordinate efforts between these campuses to reduce the errors found during this audit.

Management’s Actions Management has agreed that shifting the responsibility of updating of all attendance information, and the disciplinary records, to Reassignment Center would be more efficient and should result in more accurate data. Mr. Ladewig will handle the movement of these responsibilities to the Reassignment Center. Dr. Melton and Dr. Owen will work with the Reassignment Center in using the available technology to more efficiently update the student information system. Anticipated Timeline: 2010/2011 School Year In addition, on May 10, 2010, central administration received guidance on proper attendance practices from the Texas Education Agency’s (TEA) Director of Forecasting and Fiscal Analysis. According to the TEA, teachers are responsible for reporting the attendance in their classrooms, despite information that the student could be in other setting (i.e. DAEP, ISS, school activity, nurse’s office, etc). This information was shared with the principal and the attendance/data entry clerks.


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Report Distribution Dr. Neil Dugger Interim Superintendent Dr. Marie Morris Asst. Superintendent – Teaching & Learning Lane Ladewig Division Director – Campus Operations Dr. Alice Owen Executive Director - Technology Dr. Abby Melton Program Director - PEIMS Board of Trustees Finance Committee

ATTACHMENT A

68%

14%

13%

4%

70%

10%

10%

10%

65%

14%

19%

1%

65%

16%

17%

2%

67%

16%

16%

2%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

All Students (31,864)

Expel/JJAEP (10) ISS (4,851) OSS (1,309) DAEP (423)

09/10 Discretionary Placement of Students by Ethnic Group

1st Semester Only

American Indian

Asian

African American

Caucasian

Hispanic

ATTACHMENT B

Accuracy of Discipline Records Attendance TestingAdjustments

(Errors in ADA Period)

Loc# CampusTotal Pop

Not Tested

Sample Size

% of Records Accurately Updated

% of Records Partially Updated

% of Records Not Updated

% of Erroneous Records

(Duplications/ Overlaps/Errors)

Sample Size

% of Population

% of Attendance

Reported Accurately

% of Attendance

Not Reported Accurately

Funded Absence

reported as Unfunded Absence

Unfunded Absence

reported as Funded Absence

Error May Not Impact

Funding

002 Irving HS 102 0 102 14% 38% 43% 5% 40 39% 70% 30% 6 3 3003 MacArthur HS 95 39 56 63% 16% 20% 2% 45 47% 87% 13% 1 3 2004 Nimitz HS 50 25 25 12% 52% 36% 0% 16 32% 63% 38% 0.5 4.5 1005 UBCL 4 0 4 50% 50% 0% 0% 3 75% 0% 100% 3006 Academy HS 16 7 9 33% 44% 22% 0% 9 56% 44% 56% 2 3041 Bowie MS 37 11 26 8% 54% 31% 8% 23 62% 26% 74% 4.5 1.5 11042 Crockett MS 10 0 10 30% 50% 20% 0% 10 100% 20% 80% 8043 Travis MS 22 6 16 25% 56% 13% 6% 15 68% 0% 100% 1.5 1.5 12044 Lamar MS 9 0 9 22% 67% 11% 0% 9 100% 0% 100% 1 8045 Austin MS 16 7 9 11% 56% 33% 0% 7 44% 86% 14% 1046 Houston MS 32 14 18 22% 67% 11% 0% 18 56% 0% 100% 18048 de Zavala MS 27 11 16 13% 56% 31% 0% 15 56% 93% 7% 1102 Brown ES 3 0 3 33% 33% 33% 0% 3 100% 67% 33% 1103 Britain ES 1 0 1 0% 0% 100% 0% 1 100% 100% 0%105 Good ES 3 0 3 0% 33% 67% 0% 3 100% 33% 67% 1 1106 J. Haley ES 1 0 1 100% 0% 0% 0% 1 100% 0% 100% 1107 T. Haley ES 1 0 1 0% 0% 100% 0% 1 100% 0% 100% 1109 Keyes ES 1 0 1 0% 100% 0% 0% 1 100% 100% 0%113 Farine ES 1 0 1 0% 100% 0% 0% 1 100% 0% 100% 1114 Schulze ES 1 0 1 0% 0% 100% 0% 1 100% 0% 100% 1121 Davis ES 1 0 1 0% 100% 0% 0% 1 100% 100% 0%122 Gilbert ES 1 0 1 100% 0% 0% 0% 1 100% 100% 0%124 Stipes ES 1 0 1 0% 100% 0% 0% 1 100% 0% 100% 1

435 120 315 25% 42% 30% 3% 225 52% 52% 48% 18.5 13.5 77

Documents

Irving ISD Discipline Audits