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SAVANNAH-CHATHAM COUNTY BOARD OF EDUCATION Internal Audit Department

TO: Board of Education THROUGH: Dr. Thomas B. Lockamy, Jr., Superintendent

Dr. Ann Levett, Interim Chief Academic Officer David Feliciano, Chief of Data and Accountability Dr. Angie Lewis, CTAE Director

FROM: Kelly Crosby, Senior Director, Internal Audit DATE: February 27, 2014 SUBJECT: Report on School Guidance and Counseling Services We have completed our Audit of School Guidance and Counseling Services. Our audit report is presented in the sections listed below:

I. EXECUTIVE SUMMARY II. SUMMARY OF AUDIT CONDITIONS III. AUDIT OBJECTIVES IV. AUDIT SCOPE V. BACKGROUND VI. AUDIT CONDITIONS VII. OTHER MATTERS VIII. BEST PRACTICES

Management’s response to our report is attached in its entirety. In addition, the specific action that management has agreed to take in response to each recommendation is included in the Management Action Plan, along with who is responsible for the action and when it will be completed.

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I. EXECUTIVE SUMMARY

Legislation passed during the past several years has significantly changed the role of school counselors. In September 2000, the Georgia Department of Education (GaDOE) passed State Board Rule 160-4-8-.05, which requires school counselors to provide counseling services for a minimum of five of six full-time segments each day. These services could include:

• designing and planning a school-based guidance and counseling program; • counseling individual students or support groups; • analyzing the effectiveness of group counseling; • providing classroom guidance activities; • providing information to students, parents, teachers and administrators on

student test scores; • developing strategies for improving school climate; • implementing a comprehensive and developmental school guidance and

counseling curriculum to assist all students. By virtue of the time required to be spent providing counseling services, this bill also restricted the use of school counselors as test coordinators, disciplinarians, classroom substitutes, and other assigned duties. Other relevant legislation includes: • House Bill 149, Move On When Ready (MOWR) Act was signed into law in

April 2009. This act provides a dual enrollment opportunity for students to attend a postsecondary institution full-time during their junior and/or senior year of high school.

• House Bill 400, also known as the BRIDGE Act (Building Resourceful

Individuals to Develop Georgia’s Economy) was signed into law in May 2010. The implementation of the BRIDGE Act provides middle and high school students with career counseling and regularly-scheduled advisement to choose a focused plan of study. Students are required to choose a career area and create an Individual Graduation Plan (IGP) in order to graduate from high school prepared for college or ready to enter the workforce. Each 8th grade student is required to create an IGP during the spring semester based on his/her selected academic and career areas. The plan is developed in consultation with parents/guardians, students, and school counselors.

• House Bill 186, passed in 2011, provides and expands the career pathway

options for high school students to ensure their career and college readiness. • House Bill 175, passed in July 2012, provides students and parents with

information and access to high-quality academic and career-oriented courses aligned to State and national standards through a variety of online providers.

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• Senate Bill 289, also passed in July 2012, states that school districts must allow students to take a course offered through the Georgia Virtual School even if the course is offered at the student’s local school.

• House Bill 713 became effective July 1, 2012 and amends the Quality Basic

Education Act to delay implementation of some career and college readiness initiatives until SY 13/14, to require career education in grades K-12, as well as for other purposes related to the changing of the assessment for postsecondary readiness to the end of the eleventh grade and to mandate transitional courses.

• House Bill 283, effective May 2013, provides guidance for funding related to

school counselor-to-student ratios, as well as replaces the terminology of “guidance counselor” with “school counselor.” This bill establishes the recommended ratio of school counselors to students as 1:450; it also establishes the Quality Basic Education (QBE) formula for school counseling to include funding for one school counselor for each 450 students; however, this calculation does not include students receiving Special Education, English Language Learners, Gifted or Remedial services in the calculation. In addition, the formula only provides funding at an entry level salary. It does not include step increases based on length of service.

There are other areas of regulation, such as GA HOPE, governed by the Georgia Student Finance Commission. School counselors must understand all the current guidelines that govern HOPE so that the District’s students who may be eligible for the HOPE scholarship are provided with reliable, accurate and timely information. While all of these rules and regulations do not necessarily mandate a school counselor to perform a specific task, they all impact the role of the school counselor in the District’s schools. Each school counselor must be thoroughly knowledgeable of these criteria; school counselors are expected to be important members of the school’s team to help all students in their areas of academic achievement, as well as personal/social development and career development, to ultimately help guide all students to success. SCCPSS does not currently have a full-time, dedicated District-level position over School Guidance and Counseling Services. For the past two years, these responsibilities have been performed on a part-time basis by a retired school counselor whose focus was the District’s cohort graduation rate. For several years prior to that, school counselors were supervised by a series of staff members who had no school counseling experience. Therefore, school counselors may not have had all the support and advocacy needed to adequately fulfill their roles. Failure to provide adequate guidance and advocacy had the following negative consequences:

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• Reduction of school counselors in elementary schools - The number of school counselors was reduced due to budget restrictions in SY 10/11. Without an advocate to stress the needs of schools, students and counselors, a unilateral decision was made that elementary schools needed only a single counselor with no clerical (counselor clerk) support, without consideration of school enrollment and/or student needs. This created a budget reduction of 11.5 full-time positions and approximately $735,000.

• District-wide misunderstanding of the role of school counselors – The legislative changes noted above changed the reporting structure for school counselors, as well as their role in schools. The movement of school counseling and guidance services at the State level to the Career Technical and Agriculture Education (CTAE) initiative indicates a fundamental shift of the focus of the program that has not been communicated effectively to all stakeholders.

• Lack of scheduled professional learning opportunities – Without a District level manager, no one advocated for and ensured the availability of current training in best practices in the area of school guidance and counseling.

Overall, we found room for improvement in several areas. The following report includes four conditions where improvement is needed in order for the District’s school guidance and counseling services to better meet students’ needs. These conditions, detailed in this report, relate to a District-wide school counseling curriculum; the reliability of student data; the roles and responsibilities of school counselors; and professional development opportunities for school counselors.

II. SUMMARY OF AUDIT CONDITIONS Our Audit of School Guidance and Counseling Services has identified four conditions where improvements are needed. These conditions are stated below with identified pages where details of the condition are presented. Condition A. SCCPSS lacks a District Comprehensive and Developmental Curriculum for School Guidance and Counseling. (Pages 13-21) SCCPSS does not have a current District comprehensive and developmental curriculum for school guidance and counseling, which may be adapted to the individual schools’ needs, to ensure District students are provided with consistent and appropriate school guidance and counseling services at all school levels. (DAS Goal I) Condition B. Improvement is needed in areas of student data accuracy and reliability to ensure students’ progression to graduation. (Pages 21-29) Improvement is needed in the recording and monitoring of student data that impacts high school graduation, and implementing sufficient internal controls and

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frequent accountability measures to ensure that the data recorded are accurate and reliable as the student progresses to graduation. (DAS Goal I) Condition C. Roles and responsibilities of the school counselor need to be more clearly defined for all school levels. (Pages 29-39) SCCPSS school counselors may not be able to provide appropriate school guidance and counseling activities as required by GaDOE because of the amount of time spent in non-counseling activities assigned to them by site administration that are considered by ASCA and/or the GaDOE as inappropriate responsibilities for school counselors. (DAS Goal I) Condition D. Professional learning opportunities for school counselors and school counselor clerks need to be provided by SCCPSS Professional Learning. (Pages 39-42) Internal Audit was not able to identify any professional learning opportunities offered by SCCPSS Professional Learning for school counselors or counselor clerks. We also did not find any training opportunities for first-year school counselors or school counselors new to the District. (DAS Goal I) Other Matters. (Pages 43-44) During the course of this audit, we determined an additional area of risk that may impact school guidance and counseling services. This area of risk involves communication, not only among District staff, but also provided to community stakeholders. While we did not include this area in our audit program and did not conduct extensive tests in this area, we believe that District management should consider a further review of this area to mitigate possible risks. (DAS Goal IV) Best Practices. (Pages 44-45) In our Audit of the School Guidance and Counseling Services, we identified one area as a “best practice” in documenting counseling services as required by new legislation. (DAS Goal I)

III. AUDIT OBJECTIVES Our audit was designed to meet specific objectives. Within those objectives, we focused on areas where we identified opportunities for improvement in School Guidance and Counseling Services. The objectives of our audit were as follows:

1. Review all local, State and Federal requirements for school guidance and

counseling services to ensure the District meets all requirements, including staffing levels, certification and experience requirements, mandated reporting, etc.

2. Review District policies, administrative regulations and guidance related to school guidance and counseling services to ensure they provide adequate and appropriate direction to achieve the District goals.

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3. Review District spending for/by school guidance and counseling services to ensure funds are spent according to District guidelines and policies.

4. Document the processes for assigning school counselors to the District’s elementary, K-8, middle and high schools, and determine if these processes meet State guidelines and/or local policies, as well as provide equity for the District’s schools to meet the needs of the schools’ unique populations.

5. Review the duties and responsibilities for school counselors at the elementary, K-8, middle and high school levels to ensure that appropriate grade-level school guidance and counseling services are available and provided to the District’s students.

a. Curriculum component b. Social/emotional development component c. Progress to graduation d. Identify any obstacles to providing appropriate counseling services.

6. Review professional development opportunities for school counselors to ensure that training in current research-based exemplary strategies is provided.

7. Review data used by school counselors to ensure accurate processing of student records for progression to graduation, as well as college and career readiness.

8. Identify exemplary strategies currently in use in the District for providing school guidance and counseling services and determine if these strategies can be implemented at all school sites.

IV. AUDIT SCOPE The Audit of School Guidance and Counseling Services was conducted in the first semester of SY 13/14. The audit of this program was scheduled as the result of Internal Audit’s annual risk assessment process in 2013, which determined that school guidance and counseling services had never been reviewed by Internal Audit. The Audit of School Guidance and Counseling Services was a District-wide performance audit, not an audit of individual schools. Our audit was performed to determine if the District is providing school guidance and counseling services in the most effective and efficient ways to all District students. We used the laws and regulations of the Official Code of Georgia (OCGA), the Georgia State Department of Education (GaDOE), the Georgia State Board of Education (SBOE), and Savannah-Chatham County Board of Education policies and administrative regulations as guidance. Internal Audit did not identify or name any individual school in the audit report. We also reviewed information and best practices in the field of school guidance and counseling from the American School Counselor Association (ASCA), including the ASCA Student Standards, the ASCA Counselor Competencies, and

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the ASCA Ethical Standards for School Counselors. These resources help school counselors create comprehensive school counseling programs that focus on student outcomes, teach student competencies, and are delivered with identified professional competencies. Internal Audit reviewed research in the area of school guidance and counseling, analyzed SCCPSS data, conducted unannounced observations in all District schools, observed trainings and meetings relevant to the responsibilities and duties of the District’s school counselors. We reviewed financial budgets and expenditures for FY 2013 for guidance activities. We also conducted tests and analyses of data recorded in the District’s data systems, PowerSchool and AHRS, the District’s Human Resources System. We interviewed District and site administrators and staff, school counselors, school counselor clerks, GaDOE staff, and current and former District staff who had been involved with the oversight of school guidance and counseling services. We surveyed the District’s school counselors in all District schools at two separate times. The first survey was conducted at the end of SY 12/13 to determine the issues that school counselors identified as major concerns in their role. From this data and further research, we developed a second survey to determine more specific information related to the role of the school counselor in our District schools. Many of the surveys contained written comments, and we refer to those comments as appropriate throughout this report.

We visited all District schools and conducted a total of 52 unannounced observations, along with 22 scheduled interviews with individual school counselors or groups of school counselors. We attended and observed trainings, meetings and workshops provided by the College Board, GaDOE, District Career, Technical, and Agricultural Education (CTAE) staff, Technology staff, and Exceptional Child Education staff. We also visited planned activities for school counselors held by several colleges and universities, as well as the PROBE Fair, organized by the Georgia Education Articulation Committee, Inc. (GEAC) to disseminate information and stimulate interest in post-secondary education for students in Georgia. Our fieldwork was conducted during the period of June 2013 through December 2013. We designed our audit with specific strategies to gather the necessary information to identify areas where improvement is needed to more effectively provide school guidance and counseling services to all District students. We have identified conditions and have made recommendations to District management for consideration in making the necessary improvements. We also identified best practices used in the District.

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Our recommendations are made to District management in order to improve school guidance and counseling services at all District schools. We based our opinions on interviews, surveys and observations conducted during the course of our audit work. The Board’s District Accountability System (DAS) lists four goals:

I. To Improve Academic Achievement. II. To Ensure Fiscal Responsibility and Effective Resource Stewardship. III. To Provide a Safe and Secure Environment for Students and

Employees. IV. To Engage Parents and Other Community Stakeholders.

At the end of each Condition statement, we have identified the DAS goals that are most likely affected by the findings identified in the Condition. Internal Audit has made recommendations to help support the achievement of these goals. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

V. BACKGROUND Currently there are 76.5 school counselors assigned to 54 school sites, including charter schools. Two of the District’s four charter schools have school counselors. The following chart provides the breakdown:

School Level # of Sites # of School Counselors Elementary Schools 24 24 K-8 Schools 7 13 Middle Schools 8 12.5 High Schools 11 25 Charter Schools 4 2 Total 54 76.5

According to the Georgia State Department of Education’s Earning Sheet for FY 2014 for Chatham County, the District earned 66.16 school counselor positions in K-12. In our audit work, we determined that some District schools were using additional funds, such as monies from Title I or Academies, to pay for one or more part-time school counseling positions to help meet the needs of students in their schools.

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Funding and School Counselor-to-Student Ratios - HB 283 provides the current guidance related to QBE funding for school counselors, stating that “program weights, when multiplied by the base amount, shall reflect sufficient funds to pay the beginning salaries for at least one school counselor for every 450 full-time equivalent students.” Beginning in FY 2015 and thereafter, program weights for ESOL and programs for students with disabilities shall also earn school counselor funding. Beginning in FY 2016 and thereafter, program weights for intellectually gifted students and the remedial education program shall earn school counselor funding. Currently, these four groups of students are not included in the QBE funding formula for counselors. This guidance also states that the “duties and responsibilities for such school counselors shall be established by the state board to require a minimum of five of the six full-time equivalent program count segments of the counselor’s time to be spent counseling or advising students or parents.” The District’s school counselors are an experienced group of professional educators, all holding at least a Masters Degree in School Counseling, which is the minimum level of education that an educator must have earned in order to be hired as a school counselor in the state of Georgia. Georgia no longer requires school counselors to be teachers with at least three years of teaching experience before becoming a school counselor. Therefore, some SCCPSS school counselors have never been a teacher in the classroom, while others have had actual teaching experience. Internal Audit analyzed data for 72 school counselors to determine their years of experience and the impact this may have on the cost to the District for salaries and benefits and to determine how the funds that the State allocates to the District compensate for the cost of providing school guidance and counseling. From our review, we determined the following:

• Three school counselors have less than five years of experience. (SCCPSS did not have any school counselors in their first year of school counseling in SY 13/14.)

• Twenty-two (22) have 5-10 years of experience. • Eighteen (18) have 10-15 years of experience. • Nine have 15-20 years of experience. • Fifteen (15) have 20-25 years of experience. • Two have 25-30 years of experience. • Two have 30-35 years of experience. • One has 35-40 years of experience.

Forty-seven (65%) school counselors have over ten years of experience in education, with 20 counselors having over 20 years of experience. Therefore, the majority of District school counselors make salaries significantly higher than the amount the State allocates. The District does not have any school counselors who earn only the beginning salary of a school counselor.

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While the State establishes the funding based on the ratio of one school counselor for every 450 full-time equivalent students, professional standards in the field of school guidance and counseling recognize the 1:450 ratio as too high to effectively provide services. The American School Counselor Association (ASCA) recommends a school counselor-to-student ratio of 1:250. The U.S. Department of Education National Center for Education Statistics published a 2010-2011 comparison of states’ school counselor-to-student ratios. At that time, Georgia’s ratio was 1:471. All but New Hampshire, Vermont and Wyoming had ratios over the ASCA recommendation, with the highest ratio of 1:1,016 in California. Internal Audit conducted an analysis of the District’s school counselor-to-student ratio using the SY 13/14 school counselor assignments and student enrollment as of January 2, 2014. The following was determined:

• Only one school counselor was assigned to each of the 24 elementary schools. These schools ranged in enrollment from 428 to 941 students, for a District total of 15,784 elementary school students. The District average for school counselor-to-student ratio for elementary students was 1:658. However, half of the individual elementary schools had school counselor-to-student ratios higher than the District average. Twenty of the District elementary schools exceed the school counselor-to-student ratios of 1:450.

• There are 13 school counselors assigned to the District’s K-8 schools. The assignments range from one school counselor at one K-8 school of 573 students to three school counselors at a K-8 school of 1,635 students. The District average school counselor-to-student ratio for K-8 students is 1:467.

• There are 12.5 school counselor positions assigned to the District’s middle schools which range in enrollment from 449 to 991 students. The total number of students in the middle schools was 5,470. All but two of these schools had either two or 1.5 school counselors assigned; the remaining schools each had one counselor. The District average school counselor-to-student ratio for middle school students was 1:438.

• There are 25 school counselors assigned to the District’s 11 high schools, including Early College, with the enrollment range of 194 to 1,166 for a total of 8,300 high school students. Two high schools had only one school counselor; five high schools had three school counselors each. The other four high schools had two school counselors each. The District average school counselor-to-student ratio for high school students was 1:332.

• There are four charter schools; two of them had one school counselor each. There were a total of 1,262 students in the charter schools. The average school counselor-to-student ratio for charter school students was 1:631.

• There were 36,888 District students in this analysis, for a District school counselor-to-student ratio of 1:482.

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All but two of the District’s high schools have one full-time school counselor clerk position. All but one of the middle schools have a part-time school counselor clerk position; one middle school has a full-time school counselor clerk position. Three K-8 schools have a part-time school counselor clerk position; four K-8 schools do not have a counselor clerk position. None of the elementary schools have school counselor clerk positions. State Legislation - Impact on School Guidance and Counseling - The area of school guidance and counseling in Georgia public schools has changed dramatically with several legislative initiatives - House Bill (HB) 400, BRIDGE Act (Building Resourceful Individuals to Develop Georgia’s Economy Act); HB 149, MOWR Act (Move On When Ready); HB 186 (provides and expands career pathway options and focused programs of study); and HB 713 (requires career education in grades K-12) - that require more focused attention to college and career readiness for all Georgia students. The GaDOE website states:

Today’s school counselors are vital members of the Career, Technical and Agricultural Education team. They help all students in the areas of academic achievement; personal/social development and career development, ensuring today’s students become the productive, well-adjusted adults of tomorrow. Gone are the days of “guidance counselors” sitting in their offices and only handing out college applications or dealing with the “problem kids.” Today’s professional school counselors guide their students through three parallel paths that lead to one destination: success. Rather than providing a service just to students who need them, school counselors manage comprehensive programs for every student.

The GaDOE has provided tools and resources on their website to help school counselors become more aware of what they should be doing to comply with the recent laws. Links are provided for elementary, middle and high school counselors to specific guidance and strategies to help our students graduate from high school prepared and ready for college and/or career. School counselors have taken on additional responsibilities in their role to ensure continuous improvement in students’ success. School counselors must be accountable for assessing students’ needs, establishing measurable goals, and measuring the results of guidance and counseling activities. They are expected to be a part of the team of educators who collect, disaggregate, and analyze data to determine areas of student strengths and areas of needed improvement. Also, from this data they are also expected to develop a proactive school counseling program which provides the services and guidance curriculum to help all students succeed. The American School Counselor Association (ASCA) has long been recognized as the professional organization which provides the “gold” standards for

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implementing quality programs of school guidance and counseling services. ASCA has identified four skills that help to articulate the new role of school counselors – leadership, advocacy, collaboration and systemic change. They identified four additional components of an effective 21st century school counseling delivery system – guidance curriculum, individual student planning, responsive services, and service support. As a result of HB 1187 (A+ Education Reform Act of 2000), as well as helping to provide services for all students who are “at risk of not being at promise,” school counselors must develop guidance and counseling programs that are more results driven. The GaDOE has provided recommended time allocations using the ASCA National Model, to establish the following guidelines for elementary, middle and high schools in the form of a Guidance and Counseling Activity Log: Elementary Middle High Guidance Curriculum 35-45% 25-35% 15-25% Individual Student Planning 5-10% 15-25% 25-35% System Support 10% 10% 10% Responsive Services 30-40% 30-40% 25-35% Non-Counseling Activities 5% 5% 5% The log with its suggested timeline structure is also designed for school counselors to use as a source of data collection and assessment of their individual school’s guidance and counseling program, as well as complying with the guidelines of HB 1187, which provided for comprehensive reform of the delivery of education services in Georgia at the PreK, elementary, secondary and post-secondary levels. As stated on the GaDOE website:

This time log can be used to analyze the distribution of the school counselor’s time and the various tasks the counselor is performing and to provide baseline data for the redistribution of the counselor’s time if necessary. It is also useful for determining where more educational support may be needed. Note: If too much time is being spent on Non-Program activities, an evaluation of the Guidance and Counseling Program should be done to determine what program areas are being negatively affected and thereby not reaching all students.

Status of District Leadership over SCCPSS School Guidance and Counseling Services - With State legislation passed to reform education in Georgia that increased the involvement of school counselors in all students’ programs of study of college and career preparation, it appears that school guidance and counseling services in SCCPSS may have lost the needed focus to ensure that all services were being provided in a consistent and complete manner. From discussion with former school counselor program managers, we were told that during the late 1990s, the full-time director position over school counselors was eliminated for budgetary reasons. For the next six years, school counselors were under the supervision of various District-level Curriculum and Instruction staff (Math, Teenage Parent Program [TAPP], Physical Education), ultimately to end

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up under the direction of a retired school counselor who was over the Hearing Office as well as all social workers and school counselors. We were told by several veteran school counselors that during those six years, the direction provided by District staff in the field of school guidance and counseling services was not as effective as the previous full-time program manager.

From 2002-2006, another retired school counselor worked part time to provide guidance to the school counselors and social workers, under the supervision of Student Affairs (formerly known as Pupil Personnel). After the decision was made that the job required full-time direction, a school counselor was hired to oversee only the school counselors. However, within a year, this position was eliminated once again due to budgetary reasons. In SY 11/12, the District hired yet another retired school counselor to provide assistance and direction to school counselors. Her primary focus was developing and implementing a process to ensure graduation cohort data was accurate. During interviews with school counselors, we were told several times that there is a strong feeling that school guidance and counseling is not valued in this District. We were also told that as a result of the lack of having a District program manager for support, guidance and advocacy, school guidance and counseling services are provided in different ways with different directions in some schools. Also, the roles and responsibilities of the District’s school counselors are impacted by many “other duties as assigned” by the site administrators. From our interviews and observations, it appears that some school counselors have become the “extra administrator” at their schools with walkie-talkies in hand in order to be accessible to the administrators. For example, they are pulled into situations requiring immediate disciplinary action and consequences, instead of long-term counseling services which may be needed to change a student’s negative behavior.

The conditions in this report reflect specific areas in which Internal Audit has identified risks to the District’s school guidance and counseling services. These risks may reflect the impact of the issues of funding, school counselor-to-student ratios, the lack of District leadership management assigned over school counseling, data collection struggles, as well as additional responsibilities placed on the District’s school counselors which are not related to school guidance and counseling. In our overall opinion, school guidance and counseling services, as well as school counselors, have not received the District’s support or the attention that these professional school counselors and their field of expertise require.

VI. AUDIT CONDITIONS Condition A. SCCPSS lacks a District Comprehensive and Developmental Curriculum for School Guidance and Counseling. SCCPSS does not have a current District comprehensive and developmental curriculum for school

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guidance and counseling, which may be adapted to the individual schools’ needs, to ensure District students are provided with consistent and appropriate school guidance and counseling services at all school levels. (DAS Goal I)

Details of Condition A As stated in the Background of this report, the District has not had a stable, full-time program manager position for school guidance and counseling services for several years. From our interviews and observations, Internal Audit determined that SCCPSS school counselors are professional educators who are diligently working with the students in their schools. They know what a quality comprehensive and developmental school guidance and counseling program should look like; however, they are frustrated in their lack of opportunity to implement a quality program due to several factors. Those factors include the lack of District leadership and advocacy, and school counselor-to-student ratios which are higher than ASCA’s recommendation of 1:250 and the State’s recommendations of 1:450. During our observations and interviews with individual school counselors, we were told numerous times that the District should follow the ASCA guidelines for developing a comprehensive and developmental school guidance and counseling program. Several school counselors provided examples of daily schedules for an elementary school counselor, an elementary school guidance plan, classroom lesson plans, comprehensive school counseling plan, and a middle school guidance & counseling program. They indicated to us that they had individually developed these documents and used the ASCA resources in their preparation. A former District Program Manager provided a copy of the SCCPSS Elementary School Counselors’ Manual (2009-2010). The retired school counselor who worked for the District in a part-time capacity as Program Manager also provided several guidance plan documents. However, none of these were identified as documents that all District schools were directed to use. We were also told by some school counselors that they are aware of the need for having a comprehensive and developmental program. However, they stated that they would not be able to follow a comprehensive and developmental program because of the current nature of their positions at their schools; the increased non-counseling duties assigned to them by their administrators and the increased numbers of students who have personal social/emotional issues require additional time and attention that would normally be devoted to such a plan. Lack of a stable, full-time, dedicated District leadership position for School Guidance and Counseling Data from the September 2013 survey of District school counselors indicated that they were not given any current District guidance or direction. Responses from 67% of the participating school counselors answered “no” when asked if they had

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access to a current District Manual as an SCCPSS school counselor. When asked to whom do they go for pertinent information related to school guidance and counseling,

• 21% responded site administration; • 12% responded District-level personnel; • 56% responded other school counselors; and • 12% responded “there is no one.”

Other related comments from SCCPSS school counselors in this survey state:

• There is a lack of consistency in implementation, District-wide support, and understanding of the ASCA model and the role of a comprehensive ASCA based school counseling program and what a professional school counselor can do.

• There is not even one school that has been recognized as a RAMP (Recognized ASCA Model Program) school for their guidance department! We tried to meet regarding this in the past and were told to stop. Really? Wouldn't the district want schools to be nationally recognized for their counseling programs? We need to be working together.

• Morale is low among counselors due to lack of leadership. AGAIN, we do not have a program manager.

• We need someone to contact, yet we often don't know who our mentor is, or who to call, so we rely on each other but sometimes other counselors aren't sure of the question you ask.

• For the last few years we did have someone in the district we could go to for help but that position is no longer so we are floundering. We need a district coordinator and more support from district staff. We need more counselors in each school to be able to deal with all the issues that our students are facing. CCRPI has too many responsibilities on top of what we already do, and without additional trained counselors, something is going to get put to the side. My fear is that it will be those students with emotional concerns and those students that are struggling academically that we won't have time to address. It's not fair to us or to our students that we continue to be stretched so thin to the point that we are not effective. The students of SCCPSS deserve better and I would hope that 208 would want to treat us better before we all burn out.

• School Counselors need a strong, competent, hard-working Program Manager at the District level who will ADVOCATE for the appropriate use of School Counselors; adherence to mandated counselor to student ratios; and communicate and educate effectively in a timely manner about pertinent issues. The Program Manager should have proven experience as a stellar school counselor who, ideally, has experience at all 3 levels, but at least 2.

• District leadership for school counselors ended last school year. No transition plan has been shared for where counselors should be turning for leadership in advocating for, developing, and continuing our ASCA based professional school counseling programs aside from a suggestion that a

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point person would be identified at each level. This has not happened yet. Counties our size traditionally have at least one full time district level program manager, if not one for high school and one for K-8. This leadership position in our district has often been part time, one with a high turnover rate, and has therefore handicapped the person in it by overwhelming them with high expectations for management of an already disjointed district program without giving them a realistic role in which to address the district school counseling program from.

• I have sincere hope that this audit can help highlight some constructive ways to address some of the inconsistency in our department and better clarify our roles for both us as counselors as well as for our administration. Consistency will only help better provide for all students in the district, no matter what school they attend.

School Counselor-to-Student Ratio We have provided information in the Background of this report showing that the SCCPSS school counselor-to-student ratio exceeds the ASCA recommended ratio as well as the ratio recommended by GaDOE. The State of Georgia currently only provides funding for 66.16 of the District’s 76.5 counselors, with SCCPSS providing the difference through local funding. Without a stable, full-time, dedicated District leadership position for School Guidance and Counseling to monitor, advocate and provide guidance to our schools, the focus on funding has allowed school counselor-to-student ratios to become too large in many schools, especially the majority of elementary schools, to provide effective school guidance and counseling services. Comments from school counselors from the September 2013 survey state:

• Elementary schools should be staffed with counselors according to the number of students enrolled at the school. Several years ago, only one counselor per Elementary was allowed. That is impossible and ridiculous to expect us to be effective in a school of 600+ or to expect us to get through the year without a mental breakdown!

• We need a district coordinator and more support from the district office. More counselors in each school would also assist in many ways and allow us to help more students reach academic goals and help during personal crises. Students today are facing many issues and we are not able to help because we simply do not have the time. We need more counselors in the building so that our counselor-to-student ratio is at a workable level.

We also provided information in the Background describing the allocation of counselor clerks to District schools. Counselor clerks are funded entirely from local funds. They are used to extend the abilities of school counselors by relieving the counselors of clerical duties, allowing counselors to focus on providing services to students. Currently, elementary schools do not have a counselor clerk. The majority of K-8 and middle schools have a half-time counselor clerk, and the majority of high schools have one full-time counselor

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clerk. In our opinion, the District needs to reassess the counselor clerk position and consider providing a full-time counselor clerk position to all schools. Requirements for data collection related to the College and Career Readiness Performance Initiative (CCRPI) and additional school counseling recordkeeping tasks to ensure reliability and accuracy of student records have increased the amount of time that school counselors must use for records management. This decreases the time that school counselors should spend in direct counseling activities in helping to meet the needs of students. In several discussions with District management during the course of the audit, Internal Audit was told that a stable, full-time, dedicated District leadership position for School Guidance and Counseling has been developed; applications have been reviewed and interviews arranged. We were told that the goal was to have the newly-hired stable, full-time, dedicated District leadership position for School Guidance and Counseling “on board” in January 2014. As of the writing of this draft audit report, Internal Audit has been told that a person has been selected for this position and should be on the Board of Education agenda for approval in January. Internal Audit recommends one of the first tasks for this staff member should be to review and re-evaluate the allocation of school counselors and counselor clerks and reassess the distribution of these positions to reflect recommended school counselor-to-student ratios that are more in line with ASCA and GaDOE guidelines. In addition, the workday calendar for school counselors should be evaluated to ensure they are available at the times when they are most needed. Review of School Accountability Plans We reviewed a judgmental sample of 15 school accountability plans from SY 12/13 - six elementary schools, three K-8 schools, three middle schools, and three high schools. While we did not find any specific goals and objectives for school counselors, we determined that each of the elementary schools’ plans listed at least one focus area where school guidance and counseling services were involved; two of the K-8 schools listed at least one area; each middle school listed one area; and the high schools listed three areas. The primary strategies listed where school counselors are used were: • Character Counts education • Bullying interventions (including sexual bullying and cyber bullying) • Problem-solving strategies in schoolwide behavior management plans;

Positive Behavior Intervention Strategies (PBIS) • Conflict resolutions • Lowering student absentee rate • Increasing graduation rate

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• Increasing parent awareness/involvement – transition activities, GaCollege411, PTA, open houses and parent nights

We concluded from our review that generally the school counselor may be involved in the development of the school’s annual plan. It appears that the school counselor becomes more involved in Focus Area 3-Continuous Growth of Student Academic Achievement in the School Accountability Plan at the high school level as the student progresses to graduation. However, we did not note any reference made to preparation for college and career readiness. The actual document for the School Accountability Plan appears to need revision to reflect the current focus and initiatives related to CCRPI data. Also, the listed primary strategies of school counselors did not reflect any involvement in career cluster activities. Lack of a Current School Counselor Evaluation Tool In our research of school guidance and counseling services in Georgia, we noted that the Georgia School Counselor Evaluation Program (GSCEP) and the Georgia School Counselor Evaluation Instrument (GSCEI) were developed in 1990 and revised in 2006. The GSCEP is the annual evaluation program for school counselors which relies on observations, review of records and optional staff and student surveys. The GSCEP’s manual includes:

• Procedures for Implementing the GSCEP, • The Georgia School Counselor Evaluation Instrument (GSCEI), and • The Georgia School Counselor Duties and Responsibilities Instrument

(GSCDRI). THE GSCEI is organized into four broad categories called “tasks.” They are:

• Establishes and Promotes School Guidance and Counseling Program. • Implements and Facilitates Delivery of Counseling Services. • Implements and Facilitates Delivery of Guidance Services. • Consults with School or System Staff, Parents and Community.

Our review of these documents indicated that the information is still generally relevant and appropriate. There is valuable general information regarding the types of activities that should be included in a quality school guidance and counseling program. However, no mention is made of the latest focus on school guidance and counseling’s relationship to CTAE or the State’s direction of school counselors’ involvement in students’ college and career preparation, including career cluster activities, career pathways, individual graduation plans, or collecting CCRPI data. In discussions with several District principals and school counselors, we were told that this evaluation tool is “antiquated and not specific enough” and needs to be updated to reflect what school counselors are supposed to do. One principal told us that a tool similar to TKES, noting different levels of performance with more options on a scoring rubric, is needed for the evaluation of school

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counselors. This principal stated that the “role of the school counselor is so much bigger than the old evaluation” and also told us that SCCPSS needs to develop their own instrument if the State is not going to provide one in a timely fashion. This principal also suggested that a group of administrators and school counselors collaborate to develop a District tool and volunteered to be a part of such group. We were told by several school counselors that they were not pleased with the current evaluation process that site administrators used. Two comments from the survey of school counselors were:

• I personally feel undervalued in this county as a school counselor. There is so much more I could do in the way of college planning, scholarship advising, parent communication, career guidance, etc. I spend an enormous amount of my time on data entry and data management. Our evaluation is an illustration of the value placed on us, as it hasn't been updated in years and doesn't reflect any of the changes in our role at the state level like the BRIDGE Bill. The fact that there is no district professional recognition method for counselors is another. There is a teacher of the year, and instructional support person of the year for all other roles in the school, but nothing for counselors.

• Management of school counseling programs varies school to school based on school leadership. The duties and responsibilities of each school counselor are determined in large part by their administrator, and what that administrator's view of school counseling is. Therefore the students in our district get a vastly different counseling experience school to school. Without an evaluation model that accurately reflects in detail what school counselors should be doing based on the ASCA model, counselors are left powerless to advocate for appropriate duties as they can receive a poor evaluation if they don't prioritize what the ever changing leadership determines that year should be the counselor's focus. While some administrators have a knowledge and value for the professional school counselor model, others have a dated view more in line with the duties of an old school "Guidance Counselor" who builds schedules and enters data in some back office.

We contacted Dr. Myrel Seigler, GaDOE Program Manager for School Guidance and Counseling, to determine the State’s plans to revise the current GSCEI. Dr. Seigler told us that the GSCEI is currently the “only tool” that is “out there” for evaluation of Georgia school counselors, but some school systems may have their own. He suggested that SCCPSS may want to go ahead and consider creating their own, since it may take two years for a revised State evaluation tool. He told us that there is a plan to revamp the evaluation tool and Jackie Melendez, GaDOE Program Specialist in School Guidance and Counseling, is using the GA Rules and State Standards, along with involvement from the Georgia Association of School Counselors (GASC) to develop a new evaluation

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tool. Dr. Seigler stated that the House was “urging” a resolution to develop a comprehensive developmental plan for school guidance and counseling, which would include an appropriate evaluation tool. He also stated that “if Dr. Barge stays in his position, then the focus will remain in this direction.” We also had several discussions with Jackie Melendez during the course of the audit. In Fall 2013, the SCCPSS CTAE Director requested that Ms. Melendez provide a workshop for SCCPSS school counselors to provide current information regarding school guidance and counseling, as well as their role with CCRPI and CTAE. The workshop was held in November 2013. Ms. Melendez proposed several recommendations in her evaluative summary of this workshop. One of these recommendations was “Develop an appropriate and relevant system school counselor evaluation instrument.” Other recommendations from Ms. Melendez relative to this condition are:

• Identify District school improvement goals and objectives for school counselors.

• Develop a Savannah school counselor comprehensive and developmental curriculum and plan of action to meet system goals. This would require a long-term process of strategic goals and objectives, establishing of timelines, innovative practices, accountability and leadership.

• Establish an advisory committee to assist with the planning and implementation of a comprehensive program that includes a professional learning priority list.

ASCA describes very specific School Counselor Competencies, National Standards for Students, Ethical Standards and School Counselor-to-Student ratios. The 2013 ASCA National Model establishes guidelines for school districts to use in developing a comprehensive and development program. Regarding school counseling programs, ASCA states:

School counselors should possess the knowledge, abilities, skills and attitudes necessary to plan, organize, implement and evaluate a comprehensive, developmental, results-based school counseling program that aligns with the ASCA National Model.

GaDOE provides K-12 Quality Core Curriculum Standards for Guidance under two strands, Self Knowledge and Educational and Occupational Exploration. Along with these resources, GaDOE also provides guidance for elementary and middle school career awareness and exploration. The lack of a stable, full-time, dedicated District leadership position for School Guidance and Counseling to provide support, oversight and advocacy for school counselors appears to be the primary cause for not having a comprehensive and developmental school guidance and counseling program.

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The effect of not having full-time, stable District leadership presents the risk that all District students in all District schools are not receiving consistent, complete and quality school guidance and counseling services.

Recommendations for Condition A

Internal Audit recommends to Academic Affairs: 1. Establish a full-time, stable, dedicated District leadership position over School

Guidance and Counseling, with the following priorities: a. Develop District goals and objectives for school guidance and counseling

services. b. Develop a District school guidance and counseling comprehensive and

developmental curriculum, with a plan of action to meet the District’s goals and objectives for school counseling services.

c. Evaluate the allocation of school counselors and counselor clerks to ensure that District resources are best used to meet the needs of the students.

d. Evaluate school counselors’ workday calendars, to ensure they are available during necessary peak times in school sites.

e. Reassess the distribution and the needs of elementary vs. K-8 school counseling positions.

f. Evaluate the use and allocation of the counselor clerk position to consider full-time counselor clerk positions at all K-8, middle and elementary schools. Review and revise the counselor clerk job description to ensure that it accurately matches the appropriate duties and responsibilities needed for the job.

g. Develop strategies to improve collaboration and communication with school counselors and CTAE teachers.

2. Identify District school improvement goals and objectives for school counselors.

3. Develop an appropriate and relevant SCCPSS school counselor evaluation tool.

4. Develop and coordinate regularly planned, frequent grade level (elementary, K-8, middle, high school) meetings for school counselors to share information and focus on relevant issues. Include vertical team meetings when appropriate.

5. Establish procedures to develop a District-wide School Counselor of the Year Program modeled after the ASCA and GSCA models.

Condition B. Improvement is needed in areas of student data accuracy and reliability to ensure students’ progression to graduation. Improvement is needed in the recording and monitoring of student data that impacts high school graduation, and implementing sufficient internal controls and frequent accountability measures to ensure that the data recorded are accurate and reliable as the student progresses to graduation. (DAS Goal I)

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Details of Condition B

Internal Audit conducted several data tests to determine if student data used by school counselors were accurate and reliable to ensure timely processing of student records that support students’ progression to graduation. In August/September 2013, we selected a judgmental sample of 105 transcripts from 10th, 11th and 12th grade students currently enrolled in the District’s high schools and programs, including Early College and Ombudsman. We reviewed data in PowerSchool including transcripts, historical grades, enrollment history, and community service; we reviewed the documentation in the student’s permanent record including copies of report cards, transcripts, community service validation documents and records from previous out-of-district schools. All documents found for each student were reviewed. There were 33 transcripts which reflected discrepancies in the data reviewed. Internal Audit interviewed the school counselor(s) at each school where these students were enrolled. The thirty-three transcripts with discrepancies represent 31% of the total sample across these 12 sites; only one site did not have discrepancies on its transcripts. The discrepancies found were in the following areas:

• High school courses taken for credit in middle school were inaccurately documented on transcripts.

o Spanish 1A and 1B were not successfully completed; transcripts showed full or partial credit. (See page 23 for details.)

o Non-credit middle school courses (General Music, Science P.E. and Language Arts) indicate earned credit with credit indicated on transcript.

• Course/Credit Earned was incorrectly set up in PowerSchool. o Courses in Historical Grades show passing grade; however,

courses are not on transcript. o Earned Credit recorded in Historical Grades does not agree with

Earned Credit on transcript. o Passing grade is shown in Historical Grades and transcript;

however, no Earned Credit shown. • Previous out-of-district school’s grades and credit earned were not

entered in PowerSchool. • Other issues:

o Grades and Credit Earned were not entered for Home Schooled classes.

o “Incomplete” reflected on report card after the EOCT was taken. (“Incomplete” grades should be replaced after completion of the EOCT- see page 26.)

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Middle School Students Taking High School Courses for Credit Internal Audit interviewed school counselors from one of the District’s middle schools after a high school counselor told us how much time was being spent “cleaning up” issues on 9th graders’ transcripts. The high school counselor voiced concerns with 8th grade records, indicating the course selection and course number were “always an issue.” This was especially true with the foreign language course (Spanish 1A and 1B). Middle school counselors we interviewed were not aware that there were any concerns with their students’ transcripts. They told us that their primary role regarding school counseling involved individual counseling, conflict resolution, and the BRIDGE Act requirements. They told us that the principal does all the course scheduling and they do not know who assigns course numbers. We were told that if a high school counselor calls the middle school about a student’s transcript, they would most likely talk to the part-time counselor clerk or the information specialist, and not the middle school counselor. Internal Audit then discussed the course selection/code issue with the information specialist at this middle school. When told how the selection of the wrong course code number impacts how the course is reflected on the student’s transcript, the information specialist immediately understood the situation. Within two days, the information specialist contacted Internal Audit to inform us that she had corrected the course code numbers for the current middle school students who were taking the affected courses. The District’s World Language Teacher Specialist provided Internal Audit with a copy of the District’s procedure, “Guidance Document on World Languages Taught for High School Credit in Middle School,” along with the accompanying parent letter which must be signed. This document provides clear direction on what middle school students must do in order to take the high school courses for credit. This document can be found on ACORN. Some key statements from this document are:

• Sixth Grade Students: World Language courses will be offered as Connections classes. No High School Credit will be awarded. (There is an exception if the 6th grade student makes a satisfactory score on a System Level Language Assessment.)

• *Seventh Grade Students may take section 1A of the selected language for High School Credit. Parent Conferences and/or Parent Orientations are recommended to inform parents of student’s eligibility, explain credits, explain criteria for passing the course, and HOPE credit ineligibility. *Students successfully completing the course will receive .5 Carnegie unit credit for the class.

• *Eight Grade Students may take section 1B of the selected language after they have successfully completed 1A. Parent Conferences and/or Parent Orientations are recommended to inform parents of student’s eligibility, explain credits, explain criteria for passing the course, and HOPE credit ineligibility. *Students successfully completing the course will receive .5

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Carnegie unit credit for the class. Transcripts will be reviewed for accuracy during post-planning and Technology will roll over 8th Grade transcripts to High Schools.

• Both sections 1A and 1B must be completed with a passing grade in order for the student to receive 1 Carnegie Unit High School Credit. If section 1B is not passed, the student will not receive High School Credit for 1A. The transcript will indicate a World Language Connections Middle School Credit. Furthermore, if students do not make adequate progress or if it is deemed that the course is not suited for the student’s needs, students may be rescheduled into an equivalent grade level course without High School Credit.

MIDDLE SCHOOLS ARE RESPONSIBLE FOR ENSURING ACCURACY OF TRANSCRIPTS TO INCLUDE COURSE NUMBER AND CREDIT. WORLD LANGUAGE TEACHERS, COUNSELORS AND INFORMATION SPECIALISTS WILL MEET THE LAST TWO WEEKS OF SCHOOL TO ENSURE THAT ALL CREDIT AND COURSE NUMBER ISSUES ARE CORRECT ON TRANSCRIPTS.

The District’s guidance involving the procedures and requirements for earning middle school credit in high school, as well as the procedures for ensuring the accuracy of the credit and course number, appear to be very clear with specific steps. However, based on what Internal Audit determined in the transcript review, these procedures are not being followed by all K-8 and middle schools which offer high school courses for credit. When the middle school World Language teachers, school counselors and information specialists do not ensure that all credit and course number issues are correct on transcripts, the high school counselors have to use their time to research each student’s situation to “clean up” the student’s transcript. One high school counselor told us that this process is very time consuming and can take up to one hour per 9th grade transcript. There is the risk that the high school counselor may have to take time away from the high school guidance and counseling services to research and correct student data issues that should have been corrected at the students’ previous K-8/middle school. Internal Audit recommends that accountability processes be put in place at the K-8 and middle schools to ensure that all student data is accurate and reliable before the 8th grade records are rolled over to the high school. We also recommend that Technology put internal controls in place that prevent this rollover from occurring until the 8th grade records are accurate. Other Transcript Data Issues In December 2013, Internal Audit met with high school counselors at each school to gather information related to the discrepancies that were found in our review of the transcripts. We were told by the high school counselors that it is their

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responsibility to review the student’s transcript and conduct the research needed to determine what the issue is and to resolve the issue, at which time they provide the school’s information specialist with any corrections that should be made to the student’s record. All school counselors expressed the knowledge of how to review students’ transcripts and provided evidence of the processes that they put in place at their individual schools. However, not all schools do the same processes in the same way. The school counselors in all but one high school explained what the processes were relevant to the grade level of the students, how these processes were implemented with their students, and the roles of the school counselor and advisement teachers in monitoring these processes. One high school told us that the State mandated Teachers-as-Advisors/advisement process was not in place and not used as it had been in past years. They expressed their concern regarding this situation, but stated that the principal was in charge of this. We asked the school counselors questions related to the specific discrepancies found in the transcripts, as well as what was the status of the counselor’s review of these same transcripts. The counselors in eight high schools explained their process that would be followed to research and correct the data, but did not provide any information or documentation that these issues were corrected. In two high schools, the counselors had completed the review of students’ transcripts within the first semester of SY 13/14. One of these schools did not have any discrepancies in their transcripts that were selected in our review. The other school’s discrepancies all involved the same issue with the course not recording credit earned in Historical Grades and printed on the student’s transcript. The counselor stated that she had already provided the information specialist the names of the students which need the course data corrected in PowerSchool. District Guidance Regarding Transcript Review In October 2010, an Academic Affairs team of District staff, including the District’s part-time School Guidance and Counseling Program Manager, developed a training process and monitoring tool called the System-Wide Academic Records Management (SWARM) Protocol. In the beginning of SY 11/12, a District-level SWARM team met with school staff, including principals, information specialists, school counselors, and others, to provide non-negotiable, job-embedded professional development. The process included a hands-on review of all data required to calculate the cohort graduation rate. Once this training session was complete, the school-based SWARM Team was responsible for continuing the data analysis on an on-going basis. While the initial focus was the cohort graduation rate, principals were told that the process should be ongoing and continuous, including all students and all grade levels, not just the graduation cohort group. As part of this continuous process, the Interim Executive Director of School Governance monitors the data three times per year – Fall (the beginning of the

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school year during the principal’s pre-evaluation conference), Winter (January/February) and Spring (prior to the end of the school year). If additional concerns are noted during the monitoring visits, additional training is provided to the school-based team. In August 2012, District management reminded high school principals that the SWARM protocol was the responsibility of the school-based SWARM Team; District staff would not visit the school each year to assist with this process. Principals were reminded that they were responsible for their school’s cohort graduation rate, as well as the accuracy of all student data. District staff told us that the process is still the same, and should continue all year long during each school year. We were also told that each school has a SWARM team; the principal must be the head of the team; and the school counselors must conduct transcript audits, including reviewing tests, grades and correct courses. Internal Audit was provided with a memo titled SXB 007 outlining the “Procedures Governing Cohort Graduation Rate and Report.” This memo stated:

It is important that all of our stakeholders at the high schools understand the significant role they each play in relation to reporting and maintaining Cohort graduation data. Ultimately, it is the Principal’s responsibility to account for all students in each Cohort group regardless of enrollment status. This effort must begin from the time a student enters Grade 9. Student course planning and continuous progress monitoring must take place to ensure on-time graduation for our high school students. Principals, Assistant Principals, School Counselors, Information Specialists, Records Clerks/Guidance Secretaries, Attendance Clerks, and School Social Workers must be actively involved in this ongoing process to ensure accurate data reporting. The Cohort Graduation Rate is ultimately the responsibility of the school Principal.

A list was provided in this memo of specific tasks for principals, school counselors, information specialists, records clerk/guidance secretary, school social worker, as well as District Program Manager for School Guidance. (At this time there was a retired school counselor working part-time in this role.) There were 18 tasks listed in the steps for school counselors, including the following:

• Review student transcripts on a regular basis for errors; correct Grade 9 entry year.

• Know and maintain current knowledge of all graduation requirements. • Know and maintain current knowledge of proper course sequences,

specifically the mathematics sequence to ensure students graduate with their Cohort group.

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• Ensure that advisees are enrolled in “Pathway Courses” or Academic Electives.

• Ensure no final grade is recorded with an “I” once the student has taken the EOCT.

All high school counselors stated the importance of ongoing, regular reviews of high school transcripts. However, we determined that there is not a consistent, timely District-wide process, such as SWARM, occurring in all of the high schools. Some high schools may only be reviewing the transcripts for the Cohort, and have not completed a Fall review as the SWARM guidance provided in 2012. A reason for these differences may reflect the lack of communication from site and District staff. Other issues we noted during our interviews and observations, which involve student data related to transcripts and progressing to graduation include:

1. Individual graduation plans are maintained in PowerSchool and also in GaCollege 411. These are two different entities with different types of processes, and the systems do not “talk” to each other. School counselors expressed frustration with having students develop these plans without any specific guidance and purpose. One school counselor stated that a universal process needed to be put in place. Several high school counselors told us that none of their incoming 9th graders had individual graduation plans in either system, even though this was required of 8th graders in SY 12/13.

2. One high school counselor stated the need for “Standard Operating Procedures” (SOP) for all aspects related to student data and processes involving school counselors. SOPs would provide consistency.

3. Issues in developing the master schedule occurred in some schools, especially in planning the math sequence courses. School counselors are not always included in the development of the master schedule although the school counselors had the students’ completed advisement sheets indicating the courses that students needed. We were told that over 100 students in one school did not have correct schedules for five weeks at the beginning of SY 13/14.

4. In order to have a strong Teachers-as-Advisors program, there needs to be teacher “buy in” and administrator support. Several school counselors recommended having advisement every week, with the school counselors providing the planned schedule and lessons to the teachers.

5. Another high school counselor stated that school counselors are the “highest paid counselor clerks in the District” because non-counseling duties take up the majority of their time.

6. High schools do not have “Career Centers” as recommended by GaDOE and required by CTAE.

7. High schools have different guidelines for students to contact and meet with school counselors. One high school counselor told us his school has

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an “open-door policy” for students to contact school counselors because “student problems don’t have appointments.”

8. Earning and documenting community service hours appear to be handled in different ways at the District’s high schools.

9. School counselors at all high schools told us that there were issues with student data and course credits for students who had taken courses in Twilight. We were told that a student’s name appeared in a particular class roster with an EOCT score that the student did not take. These types of issues required more time from the high school counselors to ensure the accuracy and reliability of the data. Several school counselors stated they wished Twilight had “its own school counselor, at least its own information specialist.”

10. One high school counselor told us that there needs to be vertical planning within school counseling. Elementary, K-8, middle and high school counselors all need to understand what is required at each level and how each level impacts the next.

11. Several high school counselors told us that clarity is needed as to the process for obtaining course code information, as well as a District-wide data base of GaDOE approved course numbers.

12. Several high school counselors stated that since the Java update, it takes 5-7 minutes to generate a transcript in PowerSchool.

We also noted the following best practices in our transcript review:

1. One high school counselor told us that, at the beginning of each school year, she reviews all 9th grade transcripts, including historical grades, so that the students can be placed in correct courses. We were also told that 50% of the incoming transcripts to this school for SY13/14 were in need of correction. In this school, the school counselor does all the scheduling. As part of the ongoing transcript review, the school counselor provides a copy of the student’s transcript to each student every semester, so discrepancies can be identified and corrected in a timely fashion.

2. One high school counselor told us that he has a “working lunch” with students in order to develop relationships and help keep the students on track.

3. One high school had Freshman Parent meetings during the first semester. Only 15 parents can come at a time, and they must make reservations for the meeting. School counselors are able to provide important information in small settings with time and attention to thoroughly explain Pathways requirements for high school students.

4. One high school counselor told us that he provides “what I wish I had as a high school student.” This school’s counseling team was very upbeat and positive about their role and responsibilities. They presented their information in a very professional manner and stated they “do what it takes to keep the student foremost!”

Recommendations for Condition B

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Internal Audit recommends to Academic Affairs – School Guidance and Counseling Services Management:

1. Ensure that all K-8 and Middle Schools principals, World Language teachers, school counselors, counselor clerks and information specialists are made aware of the District’s guidance, procedures, and requirements ensuring that all credit and course code issues are resolved before an 8th grader’s records are rolled over to the high school.

2. Ensure that all appropriate personnel in K-8, middle school and high schools (principals, school counselors, information specialists, counselor clerks, school’s master scheduling team, etc.), know and maintain all proper course selection, course codes and course sequences.

3. Require all transcripts for all students to be reviewed for accuracy at the end of each school year, so students can be placed in correct courses for the next school year.

Internal Audit recommends to Data and Technology:

1. Develop internal controls to prevent the rollover of any 8th grade record to the high school until school administrators verify that all student data is accurate. Internal controls should be put in place throughout the entire year, especially at the closing of each semester, to ensure the accuracy and reliability of these students’ transcripts.

2. Meet with school counselors from each level (elementary, middle, K-8, high) to determine technology issues and concerns as these relate to student data. Provide informational training to ensure all data processes are followed correctly, and resolutions are put in place to ensure data accuracy and reliability.

Condition C. – Roles and responsibilities of the School Counselor need to be more clearly defined for all school levels. SCCPSS school counselors may not be able to provide appropriate school guidance and counseling activities as required by GaDOE because of the amount of time spent in non-counseling activities assigned to them by site administration that are considered by ASCA and/or the GaDOE as inappropriate responsibilities for school counselors. (DAS Goal I)

Details of Condition C

In June 2013, Internal Audit conducted a survey of SCCPSS school counselors to determine their top concerns during SY 12/13 in their role as school counselor in their schools. The number one issue was the “other duties” assigned by site administrators to the school counselor. These duties prevented school counselors from implementing a quality school guidance and counseling program with their students. The following are examples of the “other duties:”

• Response to Intervention (RtI) Coordinator • 504 Coordinator which includes entering data into TIENET

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• Hospital-Homebound (HHB) Coordinator • Positive Behavior Intervention Strategies (PBIS) Coordinator • Planning and Chairing Individualized Education Plan (IEP) meetings • ELL (English Language Learner) Coordinator which includes all testing of

ELL students (sometimes referred to ESOL – English for Speakers of Other Languages)

• MindSet Coordinator and Trainer (Crisis Prevention Strategies and Physical Restraint Training)

• Peer Mediation Coordinator • Parent Involvement Coordinator • School Response Team Coordinator • Required breakfast and lunch duties which take up time that could be

more effectively used in small group counseling • Coordinator of various school initiatives – fund raising, Back Pack

Buddies, Spelling Bee, Honors Recognition Programs, United Way, Dollars for Disaster, etc.

• Administering tests (GHSGT, EOCT makeups), especially in the high schools

• Registering and withdrawing students

School counselors told us that they understand why site administrators want the expertise and knowledge that school counselors bring to the aforementioned duties. Also, school counselors recognize the need for their involvement in specific activities, such as RtI, 504, HHB, PBIS, and ELL on an as-needed basis for individual students. However, when the school counselor is assigned the role of “coordinator” of these activities, the level of their involvement and time commitment increases due to the planning and implementing of the necessary processes, as well as managing of documentation records. In our unannounced observations, we observed numerous incidents where the school counselor was involved in RtI or 504 meetings with parents and/or staff for the entire school day. During those days, there was not any face-to-face time with students in any school guidance or counseling activities. One survey comment from school counselor was:

Counselors are the catchall for things going on at school. We have lunch duty and have become HHB, 504, and RTI coordinators. I am lucky to work at a school where my caseload is such that I can usually balance my non-counseling and counseling responsibilities; however, at other schools my caseload has been way above the ASCA standard of 1:250, and between schedule changes, coordinating meetings and paperwork, and putting out fires it was impossible to ensure that our BRIDGE responsibilities were met, let alone do classroom guidance.

We attended the District’s training for 504 Coordinators, and identified approximately 73% of these coordinators as school counselors. In an interview with a school counselor who is also the 504 Coordinator, we asked if she felt that

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the training was valuable and appropriate. She stated that she would have preferred the District to provide 504 training which included the basic directions on “how to” develop a quality 504 plan and meet all the guidelines, so that she could be assured that her students’ needs would be appropriately met. However, she was never provided this type of training since she was hired in the District and designated the 504 Coordinator at her school. This school counselor has never been a classroom teacher and does not have the experience of working with students under 504 plans. (Previously, Georgia required school counselors to be certified teachers with three years of classroom experience. This is not currently required for school counselor certification.) A similar discussion was held with another school counselor involving her role as the RtI Coordinator in the school. This school counselor also was never a classroom teacher and has never been trained in the types of appropriate learning strategies that may need to be put in place for students going through the RtI process. However, she has to coordinate the RtI committee who documents the students’ progress and determines if the teacher is or is not appropriately providing the strategies that have been established by the RtI committee. This school counselor stated that she was uncomfortable leading the committee assessing whether the teacher was or was not doing what was expected with the student, especially since the school counselor had never been a teacher. She understands why the school may want the school counselor to be part of the RtI committee, but she did not feel it was appropriate for the school counselor to be the RtI coordinator. Several other school counselors provided the same opinion. We also were told by school counselors who were designated as the ELL Coordinators in their school that all school guidance and counseling activities are suspended during the time of ELL testing. This appears to occur in the schools that have a significant population of ELL students and receive ELL services in a District-designated ELL program, but it also occurs in a school which has a significant number of students who may qualify for ELL services but whose parents prefer them to stay in their zoned school. Services are still provided by classroom teachers, and the testing is conducted by the school counselor. Survey comments from two different school counselors include:

• The biggest problem we have is that we are too involved in other, non-counselor related activities. The biggest for us at this school is ELL. We have a large ELL population here at our school and we must hold Language Assessment Conferences and Testing Participation Conferences for these students. That is a total of 53 conferences for us at this school. We are also in charge of the testing and the eligibility of ELL students. So essentially the first ten days of school are spent doing nothing but ELL testing. Then we are responsible for ACCESS which takes a month of our time to get all of the testing completed. Unfortunately during the times of testing, we have to put counseling on the

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back burner and deal with ELL testing. It is overwhelming, time consuming, and it completely takes us away from our students and our counseling responsibilities. While there are other responsibilities that take us away from counseling, they are not nearly as time consuming. All educators have activities at their school that must get done that are not necessarily related to the job they are asked to do. We understand that. However, ELL is such a daunting task that completely pulls us away from our students.

• Non-counselor related duties take us away from our counselor responsibilities too often. The counselors are over 504s, RTI, and ESOL. ESOL is a huge job and takes an extremely large amount of time. Often counseling is put on the back burner because of ESOL testing, or meetings that are required. The ESOL job is almost a position in itself; however, it is usually thrown on the counselors.

In other interviews with school counselors, we were told that they are also required to participate in weekly attendance team meetings, data team meetings, and other meetings called by administration. These school counselors recognize their roles and responsibilities in these meetings and take them very seriously. We were never told that they felt their participation was inappropriate or not necessary. However, if these meetings occurred during the school day, then these were required meetings that consumed time that could be used in direct or indirect guidance and counseling services with students. We also observed several elementary school counselors spending time with one or more students’ cases involving the Department of Family and Children’s Services (DFACS). As mandated reporters, the school counselor is obligated to follow the protocol in these situations, which may require several hours during one school day or spread out over several days. We observed one school counselor and principal in telephone conversation with DFACS personnel for over an hour concerning one child’s case. This type of attention is not only required but needed to help protect the safety and well being of our students. Every school counselor recognized the need for their professional involvement. However, when only one school counselor is assigned to an elementary school and the elementary school serves a high-needs population, there is the risk that school guidance and counseling activities planned for other students may be canceled frequently. One of our elementary school counselors, assigned to a school with over 800 students, showed us a notebook of a significant number of documented DFACS cases with numerous time logs indicating the time spent just during the fall of SY 13/14. In other unannounced observations, we observed school counselors involved in discipline situations. One was responsible for supervising a child who was not engaged in the classroom learning situation and was leaving the classroom of his own accord (known as a “runner”). The daily schedule of school guidance and counseling activities had to be altered because of this situation. Another

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situation involved a counselor being called in to diffuse a classroom disruption. Again, this school counselor’s daily schedule was affected by this situation. Both of these school counselors were given walkie-talkies to allow site administration to locate them in case of specific situations. Survey comments related to this situation included:

We are not administrators and should not be used to perform administrative tasks at any time. Some Elementary schools treat counselors as the 3rd or 4th AP, but that negatively affects the vital relationship of unconditional positive regard that we strive to build with our students so that they will feel comfortable talking with us when they need to. Moreover, our training is not the same as an administrator. We are the only professionals in the building trained as counselors and our responsibilities need to reflect that.

In interviews with school counselors, several commented that they were concerned that students might view the school counselor as the disciplinarian, and not as an adult whom the student can trust and come to for any concern or crisis without any fear or judgment. According to ASCA guidelines, the school counselor’s role is to provide counseling to students who have disciplinary problems, not performing disciplinary actions or assigning discipline consequences. Several of our observations in elementary and middle schools involved school counselors conducting unplanned parent conferences. There appeared to be a parental concern and the administrator asked the school counselor to come immediately to participate in the conference. At this time, if there was a daily classroom guidance activity or a small group guidance lesson planned, including required career cluster activities, the counselor’s schedule was altered and the students involved were not able to meet with the school counselor. We also noted that some elementary schools schedule school guidance and counseling as a “special” just like art, music and physical education. In this type of situation, there is the risk that an entire class or students will not receive the planned school guidance and counseling activity when a counselor’s schedule is changed. This also disrupts the classroom teacher’s schedule; when students are not provided the planned guidance and counseling activity for that class time, the classroom teacher must provide instruction during that time. In all of these observations, we noted school counselors who were professional and diligent in taking care of the situations. Numerous school counselors told us that they were aware that their site administrators needed them in all of these situations. However, when school counselors are pulled from their planned school guidance and counseling activities, there is the risk that the school counselor is not able to meet the students’ needs. Several school counselors told us that they have not been able to implement consistent and specific

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classroom guidance activities this year because of the need to handle other issues related to students’ needs and crises or other requirements that the site administrator has established. One school counselor told us that “services should be tailored to students’ needs. They should not be at the mercy of the administration.” Sometimes she felt she was an “army of one” and found that she “can always do what the principal supports” but this may not always be what the students need. Another school counselor said that when planned school guidance and counseling activities are interrupted or canceled, she feels the “message sent is that ‘you’re not important.’” Data collected from other interviews and unannounced observations provided additional information that impacts the school counselor’s jobs. School staff and parents also come to the school counselor with their personal concerns. Many of these concerns are not related to the students. The school counselors told us that they are aware that parent concerns will impact their students, so they try to provide a listening ear without becoming too involved in the personal situation. They also may try to connect the parent with another agency or outside source of assistance. The District no longer provides an Employee Assistance Program (EAP); therefore, the school counselor may be seen as an accessible resource by school staff. Several school counselors told us that they have staff and parents come to them with personal issues at least weekly. Other related survey comments from school counselors were:

• In this school, counselors are not a part of scheduling, discipline planning, or the school improvement team, and since we are not a part of the planning process then we tend to spend a lot of time in responsive services because preventative measures that could have been put into place were not put into place, and we are only thought of on the back end of the problem.

• Our role needs to be clearly defined according to ASCA National Standards. Our responsibilities should not change depending on the Principal or school we are serving. Services to students should be consistent and equal--That is what is best and right for students.

• Amount of additional responsibilities added to counselors over the past four years has limited the effectiveness of delivering counseling services to students.

• Management of school counseling programs varies school to school based on school leadership. The duties and responsibilities of each school counselor are determined in large part by their administrator, and what that administrator's view of school counseling is. Therefore the students in our district get a vastly different counseling experience school to school. Without an evaluation model that accurately reflects in detail what school counselors should be doing based on the ASCA model, counselors are left powerless to advocate for appropriate duties as they can receive a poor evaluation if they don't prioritize what the ever changing leadership determines that year should be the counselor's focus.

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While some administrators have a knowledge and value for the professional school counselor model, others have a dated view more in line with the duties of an old school "Guidance Counselor" who builds schedules and enters data in some back office.

• The CCRPI curriculum requires a lot of our time and little has been taken off our schedules to allow this necessary time.

• I work 10 extra days each year and have done so for 8 years in this district. I do that work on a district, not site, work agreement each year. Everyone knows we'll work those days, we have to as head counselors for the HOPE upload and final transcript postings, etc. But yet no one will make that a part of my contract and allow for me to benefit from the days in my leave that I accrue, or count toward my overall salary total towards retirement. Instead I'm placed on a work agreement year after year without any benefits. I LOVE my job as a professional school counselor. I believe in my role as a unique and valuable part of the school at all levels. I have much to contribute as do many of my colleagues, but I think that unfortunately the feeling of being undervalued has created a lack of cohesiveness among our department as well as an unwillingness to extend themselves in some of my colleagues.

• Academic requirements make it increasingly difficult to get into classes or to pull students. Too many non-counseling duties leave less time to spend with students and teachers.

GaDOE State Board Rule 160-4-8-.05 Guidance Counselors establishes definitions and requirements for school counseling and guidance services for Georgia school systems. This rule became effective in September 2000. The rule provides:

(1) DEFINITIONS (a) Counseling – a process where some students receive assistance from

professionals who assist them to overcome emotional and social problems or concerns which may interfere with learning.

(b) Guidance – a process of regular assistance that all students receive from parents, teachers, school counselors, and others to assist them in making appropriate educational and career choices.

(c) School counseling and guidance services – guidance, program planning, implementation and evaluation; individual and group counseling; classroom and small-group guidance; career and educational development; parent and teacher consultation; and referral.

(2) REQUIREMENTS The local board of education (LBOE) shall provide for school guidance and counseling services in accordance with state and federal laws, State Board of Education rules, and department guidelines by: o Insuring that each school counselor is engaged in counseling or

guidance activities, including advising students, parents, or guardians, for a minimum of five of six full-time segments or the equivalent.

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o Including the following as duties of the school counselor: • Program design, planning, and leadership

o Develops a written school-based guidance and counseling program.

o Implements an individual plan of action. • Counseling

o Coordinates and implements delivery of counseling services in areas of self knowledge, educational and occupational exploration, and career planning to facilitate academic achievement.

o Schedules time to provide opportunities for various types of counseling.

o Counsels learners individually by actively listening, identifying and defining issues, discussing alternative solutions, and formulating a plan of action.

o Adheres to established system policies and procedures in scheduling appointments and obtaining parental permission.

o Leads counseling or support groups for learners experiencing similar problems.

o Evaluates effectiveness of group counseling and makes revisions as necessary.

• Guidance and collaboration o Coordinates with school staff to provide supportive

instructional guidance activities that relate to students' self-knowledge, educational and occupational exploration, and career planning to facilitate academic achievement.

o Conducts classroom guidance activities related to identified goals and objectives.

o Gathers and evaluates data to determine effectiveness of classroom and student comprehension, making revisions when necessary.

o Provides direct/indirect educationally based guidance assistance to learners preparing for test taking.

o Provides information to students, parents, teachers, administrators, and, when appropriate, to the community on student test scores.

o Provides information to students and parents on career planning.

• Consultation and coordination o Consults, as needed or requested, with system/staff,

parents, and community about issues and concerns. o Collaborates with school staff in developing a strategy or

plan for improving school climate. o Follows up on counseling and consultative referrals. o Consults with school system in making referrals to

community agencies.

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o Implementation of a comprehensive and developmental guidance and counseling curriculum to assist all students.

o Insuring that each school counselor is engaged in other functions for no more than one of the six program segments or the equivalent.

The American School Counselor Association (ASCA) also provides information regarding the role of the professional school counselor. The ASCA website states:

Professional school counselors have a minimum of a master’s degree in school counseling, meet the state certification/licensure standards, and abide by the laws of the states in which they are employed. They uphold the ethical and professional standards of ASCA and other applicable professional counseling associations, and promote the development of the school counseling program based on the following areas of the ASCA National Model: Foundation, delivery, management and accountability.

In our review of ASCA standards and GA State Board Rule 160-4-8-.05, we determined that ASCA standards meet State rules and support the guidelines that Georgia has established for school guidance and counseling programs. In our discussions with SCCPSS school counselors, all told us that ASCA is the highly recognized professional organization which establishes the “gold standard” for quality school guidance and counseling programs. Several school counselors also stated that our District should strive to meet the goals and objectives that ASCA provides in the ASCA National Model. However, with the additional duties that have been assigned to many SCCPSS school counselors by the site administrators, they felt that meeting ASCA standards is very difficult to achieve. ASCA has developed specific guidance for Appropriate/Inappropriate Activities for School Counselors. Some examples of this guidance follow: Appropriate Activities for School Counselors

Inappropriate Activities for School Counselors

Individual student academic program planning.

Coordinating paperwork and data entry of all new students.

Interpreting cognitive, aptitude and achievement tests.

Coordinating cognitive, aptitude and achievement testing programs.

Providing counseling to students who are tardy or absent.

Signing excuses for students who are tardy or absent.

Providing counseling to students who have disciplinary problems.

Performing disciplinary actions or assigning discipline consequences.

Providing counseling to students as to appropriate school dress.

Sending students home who are not appropriately dressed.

Collaborating with teachers to present school counseling core curriculum lessons.

Teaching classes when teachers are absent.

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Analyzing grade-point averages in relationship to achievement.

Computing grade-point averages.

Interpreting student records. Maintaining student records. Providing teachers with suggestions for effective classroom management.

Supervising classrooms or common areas.

Ensuring student records are maintained as per state and federal regulations.

Keeping clerical records.

Helping the school principal identify and resolve student issues, needs and problems.

Assisting with duties in the principal’s office.

Providing individual and small-group counseling services to students.

Provide therapy or long-term counseling in schools to address psychological disorders.

Advocating for students at individual education plan (IEP) meetings, student study teams and school attendance review boards.

Coordinating schoolwide individual education plans, student study teams and school attendance review boards.

Analyzing disaggregated data. Serving as a data clerk. There appear to be several causes for school counselors not being able to adhere to school guidance and counseling program roles and responsibilities:

1. The roles and responsibilities of SCCPSS school counselors (elementary, K-8, middle and high) have not been specifically defined and communicated to all administrators.

2. School administrators may not be aware of the roles, responsibilities and ethical standards that professional school counselors must assume in order to provide an effective school guidance and counseling program.

3. The District does not have District leadership and oversight to ensure school counselors are able to perform their roles and responsibilities in a professional manner without interference.

4. Site administrators assign “other duties” to school counselors which may not be appropriate to the role of the professional school counselor.

5. The school counselor to student ratio at some schools is too high for one school counselor to be able to provide effective school guidance and counseling.

6. The school counselor may be the only “other person” who does not have students directly assigned to them, and may be seen as the “other professional” that can help with all issues.

When school counselors cannot adhere to the planned school guidance and counseling program, including the State-required career cluster and pathways activities, the risk exists that District students are not receiving the counseling services that they need in order to be successful. When there is not a District comprehensive and developmental program for school guidance and counseling for all schools to implement, the risk exists that District students are not

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participating in all aspects of school guidance and counseling that may help prepare the students for college and career preparation and school success.

Recommendations for Condition C Internal Audit recommends to Academic Affairs – School Guidance and Counseling Services Management:

1. Require the new stable, full-time, dedicated District leadership position for School Guidance and Counseling to develop specific District guidelines based on ASCA standards for the appropriate use of school counselors at each school level (elementary, K-8, middle, and high).

2. Consider not allowing school counselors to be “coordinators” of school initiatives such as RtI, 504, HHB, PBIS, ELL, etc.

3. Ensure that school counselors are not used to perform administrative tasks involving the discipline of students.

4. Ensure that school guidance and counseling is not scheduled as a daily “special” the way art, music, and physical education are scheduled. School guidance and counseling activities should be scheduled by the school counselor on a rotating schedule to accommodate all schedules, curriculum requirements, and needs of the students.

5. Communicate new guidelines to administrators and school counselors in a joint meeting to ensure that all understand the appropriate roles and responsibilities of the school counselor at each school level.

Condition D. Professional learning opportunities for school counselors and school counselor clerks need to be provided by SCCPSS Professional Learning. Internal Audit was not able to identify any professional learning opportunities offered by SCCPSS Professional Learning for school counselors or counselor clerks. We also did not find any training opportunities for first-year school counselors or school counselors new to the District. (DAS Goal I)

Details of Condition D

One school counselor asked Internal Audit the question – “If a first year school counselor, or school counselor new to SCCPSS, is hired in the District, how would this school counselor know what to do?” In our discussions with school counselors, we were told that the District’s New Teacher Orientation (NTO) does not provide any relevant information for school counselors. In fact, one school counselor told us she attended the NTO week in her first year of hire in SCCPSS. After two days, her principal told her not to go back since none of the information pertained to school guidance and counseling. Survey responses from school counselors indicated that 83% did not receive the appropriate professional learning in school guidance and counseling throughout the school year. Some training opportunities are offered through the annual anti-

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bullying, character education, and child abuse training that is provided through the SCCPSS Student Affairs office for social workers. The Director of Student Affairs invites the school counselors to these workshops. (At one time, school counselors were under the supervision of Student Affairs.) When school counselors were asked to indicate the best way to obtain professional development in school guidance and counseling,

• 53% indicated through District-wide professional learning opportunities with school counselors from same grade levels (elementary, K-8, middle, high).

• 20% indicated through online opportunities through other associations, professional organizations, etc.

• 9% indicated through online opportunities through SCCPSS Professional Learning Department;

• 18% indicated “other” but did not specifically define “other.” Other survey comments included:

• I have several licensures, and certifications that require professional development and have helped me grow as a professional. It would be great if I received some sort of compensation to help defray the costs of yearly renewals and required professional development. Professional Development through the school system will not count towards these required CE's unless the school system becomes an approved provider.

• There is little to no investment in or support of professional development access for counselors to support the development of an ASCA based professional school counseling program. Or really any professional development access to things like conferences, fee-based webinars, etc. that are counselor specific.

Other Professional Learning Opportunities GASC and CTAE both hold annual state conferences which provide professional learning opportunities for school counselors. Several school counselors told us that they would like to participate in these conferences, but their school did not provide the financial resources and they did not have the personal financial resources. In discussions with the SCCPSS CTAE Director during the first semester of SY 13/14, we were told that CTAE could afford to send several school counselors to both conferences. The Director extended an invitation to all District school counselors with the understanding that “first come” would be given the opportunity to go. We were told that several school counselors from elementary, K-8, middle and high schools did attend both conferences. The Director stated that she would try to make the finances available as long as the school counselor could provide a connection between school guidance and counseling and the CTAE initiatives that the State is implementing in K-12. Those school counselors that were able to attend these conferences stressed how rewarding it was to be able to have a professional opportunity to expand

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their knowledge and understanding. Also, the annual CTAE conference provides an opportunity for school counselors and CTAE educators to collaborate, build relationships, and develop a better understanding of how school guidance and counseling, and college and career awareness, support the State’s initiatives to help students succeed. GaDOE Training Internal Audit became aware of some training opportunities for school counselors to participate in State training during the end of SY 12/13. We contacted GaDOE staff to determine if we could also attend one of the regional meetings in Liberty County in June 2013. We were asked why SCCPSS was not represented by the school counselors at this meeting, as well as some of the earlier meetings during SY 12/13. We discussed with this GaDOE official the lack of District leadership for school counselors, and that possibly they did not know of these training opportunities. Also, there appeared to be a lack of full understanding by our school counselors of why school guidance and counseling was under CTAE at the GaDOE level. We were told that all school counselors should receive communication from CTAE through the CTAE Resource Network. However, when we asked school counselors if they received these communications, we were told that yes, they may have received the resources sporadically, but much of the information in the newsletter did not appear to be relevant to school counseling. Several told us that they did not even read the communication. Other School Counseling Licensures All public education school counselors in Georgia are professionals who must hold a Masters Degree in School Counseling. As educators holding GA certification through the Professional Standards Commission, school counselors must also meet certification renewal requirements, just as teachers and administrators. Some SCCPSS school counselors also hold licensures and certifications in other related counseling areas, such as mental health, play therapy, etc. These licensures and certifications also have certain renewal processes which require continuing education units or credits. We were told that if SCCPSS received a “provider number” from the GaPSC, Professional Learning would be approved to offer appropriate professional learning, such as Ethics for School Counselors, that could qualify for some continuing education requirements. Counselor Clerks Professional school counselors have had college training in preparing for their role in the school counseling profession. However, counselor clerks typically have not had any training for their role in school guidance and counseling. In our interviews with several counselor clerks in K-8, middle and high schools, we were told that they did not receive any initial training at the start of their employment as counselor clerks. One counselor clerk told us that she had to just “start the job running.” All counselor clerks told us that they had to learn what they were supposed to do from the school counselors, and that was not always easy

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because the school counselors were always busy with their jobs. We were told that staff from the District’s Records Management Department would come to the school to provide some training in how to maintain student records. All of these counselor clerks had questions regarding the forms that are used for requesting records from other schools in and out of District. School counselors need professional opportunities in continuing education for certification and licensure renewals, as well as training in all areas of their job that are not related to school counseling, such as 504, RtI, HHB, PBIS, MindSet, etc. School counselors and counselor clerks also need training in PowerSchool and TIENET. All employees become more effective when they are given opportunities for professional development, networking with their peers, and the ability to share information and best practices. When school counselors are not provided professional training opportunities, the risk exists that school counselors may not develop the necessary skills and knowledge needed to implement State initiatives in college and career awareness and preparation, or the latest best practices within the field of school guidance and counseling to help students handle academic, personal, social/emotional, and mental health issues effectively.

Recommendations for Condition D

Internal Audit recommends to Academic Affairs – Professional Learning Department:

1. Develop an annual professional learning calendar for school counselors to obtain needed training in all areas of District and school site responsibilities (504, PowerSchool, CCRPI, RtI, Hospital/Homebound, etc.), as well as professional licensing and certification requirements.

a. Consider aligning professional learning opportunities with the criteria for the Licensed Professional Counselor in Georgia credential, as well as the National Certified School Counselor certification.

b. Develop specifically-designed professional learning opportunities for “new” and/or “new to SCCPSS” school counselors. This may be offered during the New Teacher Orientation week when new educators are involved in THRIVE.

2. Develop an annual professional learning calendar for all school counselor clerks.

3. Consider becoming a “provider” for GA PSC for professional learning opportunities specifically designed for school counselors.

4. Increase the opportunities for school counselors and CTAE educators to meet together to collaborate on college and career awareness and preparation activities.

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VII. OTHER MATTERS During the course of this audit, we determined an additional area of risk that may impact school guidance and counseling services. This area of risk involves communication, not only among District staff, but also provided to community stakeholders. While we did not include this area in our audit program and did not conduct extensive tests in this area, we believe that District management should consider a further review of this area to mitigate possible risks. We identified two areas of need for increased communication between stakeholders in the area of school guidance and counseling.

1. Need for increased communication between school counselors and CTAE educators to understand the responsibilities of each group and how each provides a vital role in the success of students as they prepare for college and career readiness.

2. Need for increased and accurate communication to parents, students and the community stakeholders through the use of the District and schools’ websites regarding school guidance and counseling services.

Need for Increased Communication between School Counseling and CTAE With the State’s initiatives to improve student success through increased involvement in career awareness and activities, as well as School Guidance and Counseling Services falling under CTAE at the GaDOE, GA school districts must encourage and provide increased communication and collaboration between school counselors and CTAE educators. There is the need for intentional, frequent and regularly scheduled opportunities for school counselors and CTAE educators to meet, collaborate and discuss the implementation of career awareness and college preparation for all students. Working relationships between these two groups need to be strengthened through professional development and the opportunities to share best practices. Need for Increased and Accurate Communication to Parents, Students and Community Stakeholders On the SCCPSS website, the only reference to school guidance and counseling is the link “Student Guidance Counselors” under Student Affairs/Support Services. Information on the website at this link provides very general information related to school counseling; however the terminology has not been updated to use “school counseling” and “school counselors” instead of “guidance counseling” and “guidance counselors.” The information also has not been updated to provide the current State initiatives between school guidance and counseling and CTAE. In our discussions with management, we were told that school guidance and counseling will fall under the organization of CTAE at the

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District level. The District needs to reflect this placement on the SCCPSS public website. As of October 2013, Internal Audit reviewed the websites for all 54 SCCPSS schools. All District schools have a website. However, not all District schools have a link to their school’s guidance and school counseling program or school counselor. Information related to school guidance and counseling, as well as career awareness and college and career preparation, is not complete and accurate on all school’s websites. Students, parents and community members need to be able to access current information for all services available at each school regarding school guidance and counseling, as well as career awareness and college and career preparation. The District needs to provide specific guidance to all school sites regarding the access of information to school guidance and counseling activities on each school’s website, as well as providing relevant information for career awareness and college and career preparation pertinent to school level (elementary, K-8, middle, high). This information should be accurate and timely, use current terminology, and include an easy to find link/tab for “School Counseling” on the school’s homepage.

VIII. BEST PRACTICES

In our Audit of the School Guidance and Counseling Services, we identified one area as a “best practice” in documenting counseling services as required by new legislation. Most school counselors recorded the required career cluster activities for CCRPI data reporting purposes at their school on attendance rosters or individual paper copies for each student at the end of the year (or intermittently through the year if time was available). During our school observations, we were shown large three-ring binders providing an individual sheet for each student documenting the student’s participation in the activity, with dates included and the school counselor’s signature. Internal Audit determined that the roll out of these mandated career awareness activities occurred in the middle of the school year, with very little direction from the District and State. The elementary school counselors managed to complete the required tasks. However, we were told that the guidance for recording the data for reporting purposes was not very clear. We were provided an email that was sent on the last day of post planning of SY 12/13, requiring these school counselors to manually enter the data into PowerSchool so the District’s Student Information System and DBA Services department could submit this data to the State. In our interviews with elementary school counselors, we were told that entering of this data was handled by school counselors working several days

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after their contract dates or joint efforts between school counselors and information specialists; one principal personally recorded the data to help the school counselor. During the course of the audit, we were told by several school counselors that we needed to see the “magic” that one of the elementary school counselors had developed for this task. This school counselor had developed a spreadsheet to record the career cluster activity data with all of the details that were required. We interviewed this school counselor and were shown this spreadsheet, and all the “bells and whistles” using color coding and merging student data. The school counselor told us that he felt that developing this spreadsheet would be more efficient and would provide a more effective way of documenting these activities. At the end of the school year, the spreadsheet was provided to Student Information and DBA Services, and the information was uploaded directly into PowerSchool. According to both the school counselor and the Director of Student Information, the upload took only a matter of minutes and all the data was accurately recorded showing no errors. The spreadsheet was much easier and less time consuming to update than paper records; the upload to PowerSchool saved the school counselor time at the end of the year and increased the accuracy of PowerSchool by reducing the opportunity for data entry errors. This spreadsheet has been shared with other school counselors for use in SY 13/14, and the elementary school counselor has been asked to provide the training to the other school counselors.

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Signature Page for Audit of School Guidance and Counseling Services ____________________________ _________________________ Dr. Thomas B. Lockamy, Jr. Dr. Ann Levett Superintendent Chief Academic Officer _____________________________ _________________________ Dave Feliciano Dr. Angie Lewis Chief of Data and Accountability CTAE Director _________________________ _________________________ Kelly J. Crosby Ginger Masingill Senior Director, Internal Audit Academic Auditor ______________________________ _________________________ Leah Underwood Lucy Hazlip Senior Internal Auditor Internal Audit Clerk