District of Columbia Public Schools: Enrollment Count Still Appears
Vulnerable to Errors (Testimony, 03/13/98, GAO/T-HEHS-98-91).

Pursuant to a congressional request, GAO discussed its recent report on
the enrollment count process that District of Columbia Public Schools
(DCPS) used in school year 1996-97.

GAO noted that: (1) in spite of some changes in DCPS' enrollment count
process in response to criticisms, the 1996-97 count process remained
flawed in several respects; (2) for example, the Student Information
System (SIS) continued to have errors, such as multiple enrollment
records for a single student and weaknesses in the system's ability to
track students; (3) in addition, verification of student residency
remained problematic; (4) although DCPS made some changes in its
enrollment count process for the 1997-98 school year in response to
GAO's recommendations and plans to make more, the larger systemic issues
appear to remain mostly uncorrected; (5) consequently, fundamental
weaknesses still remain in the enrollment count process, making it
vulnerable to inaccuracy and weakening its credibility; (6) for example,
DCPS staff report that although an important internal control--duplicate
record checks--has been implemented for SIS, additional internal
controls are still lacking; (7) several DCPS enrollment and pupil
accounting procedures continue to increase the possibility of multiple
enrollment records for a single student; (8) GAO is concerned that
duplicate record checks alone may not be sufficient to protect the
integrity of SIS, given the many possiblities for error; (9)
furthermore, the enrollment count may still include nonresident
students; (10) more than half of DCPS' students have either failed to
provide the residency verification forms or have provided no proofs of
residency to accompany their forms; (11) GAO questions the
appropriateness of including students who have failed to prove residency
in the official count, particularly students who have not even provided
the basic form; (12) in addition, because DCPS has not yet monitored and
audited residency verification at the school level, additional problems
may exist that are not yet apparent; (13) proposed new rules governing
residency will help DCPS deal with residency issues; (14) until these
issues are fully addressed and resolved, however, the accuracy and
credibility of the enrollment count will remain questionable; (15) in
GAO's more recent discussions with DCPS officials, they acknowledge that
more needs to be done to improve the enrollment count process,
particularly in the areas of further strengthening DCPS' automated
internal controls and addressing the nonresident issue; and (16) they
have expressed concern, however, that GAO has failed to recognize fully
the improvements DCPS made in the enrollment count process for school
year 1997-98.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-HEHS-98-91
     TITLE:  District of Columbia Public Schools: Enrollment Count Still 
             Appears Vulnerable to Errors
      DATE:  03/13/98
   SUBJECT:  School management and organization
             Public schools
             Students
             Data integrity
             Internal controls
             Attendance records
             School districts
             Data collection
             Management information systems
IDENTIFIER:  District of Columbia
             DC Public Schools Student Information System
             
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Cover
================================================================ COVER


Before the Subcommittee on the District of Columbia, Committee on
Government Reform and Oversight, House of Representatives

For Release on Delivery
Expected at 12:00 noon
Friday, March 13, 1998

DISTRICT OF COLUMBIA PUBLIC
SCHOOLS - ENROLLMENT COUNT STILL
APPEARS VULNERABLE TO ERRORS

Statement of Cornelia M.  Blanchette, Director
Education and Employment Issues
Health, Education, and Human Services Division

GAO/T-HEHS-98-91

GAO/HEHS-98-91T


(104919)


Abbreviations
=============================================================== ABBREV

  DCPS - District of Columbia Public Schools
  SIS - Student Information System

DISTRICT OF COLUMBIA PUBLIC
SCHOOLS:  ENROLLMENT COUNT STILL
APPEARS VULNERABLE TO ERRORS
============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee: 

I am pleased to be here today to assist the Subcommittee in its
oversight of the District of Columbia Public Schools' (DCPS)
enrollment count.  An accurate count of the number of enrolled
students is the cornerstone of a school district's financial needs
assessment.  Although in the past, DCPS did not receive funds on the
basis of the number of students enrolled, new budget initiatives will
soon directly link DCPS' funding to school enrollment.  Even now, the
number of enrolled students is an important factor in developing
DCPS' budget and distributing its funds.  Consequently, a valid
enrollment count process and an accurate count are critical for DCPS'
district- and school-level planning, staffing, funding, and resource
allocation. 

Today, I will discuss our recent report\1 on the enrollment count
process that DCPS used in school year 1996-97 and actions DCPS
officials report they have taken in response to our recommendations. 
Our report was prepared at your request and was in response to
criticisms raised in the past several years about the accuracy of
DCPS' enrollment count.  Specifically, you asked us to examine DCPS'
1996-97 enrollment count process to determine whether the process
appeared sufficient to produce an accurate count.  Subsequently, for
this hearing, you asked us to follow up with DCPS regarding any
actions taken in response to our recommendations. 

Our report on DCPS' 1996-97 enrollment count process is based on
interviews with and documents obtained from DCPS administrative
staff, city officials, officials in other urban school districts and
their state departments of education, officials in the U.S. 
Department of Education, and education experts.  We also visited 15
DCPS elementary and secondary schools, randomly selected according to
school level and city quadrant.  During our school visits, we
interviewed principals, school administrative staff, and teachers and
reviewed selected documents.  To follow up with DCPS regarding
actions taken in response to our recommendations, we interviewed
DCPS' Director of Educational Accountability, who is the DCPS
official responsible for the 1997-98 enrollment count, and reviewed
various documents he provided to us.  It is noteworthy that we
neither visited DCPS schools, talked with teachers and principals,
nor reviewed documents at the school level for our follow-up as we
did for our report. 


--------------------
\1 District of Columbia Public Schools:  Student Enrollment Count
Remains Vulnerable to Errors (GAO/HEHS-97-161, Aug.  21, 1997). 


   RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:1

As we reported in August 1997, in spite of some changes in DCPS'
enrollment count process in response to criticisms, the 1996-97 count
process remained flawed in several respects.  For example, the
Student Information System (SIS) continued to have errors, such as
multiple enrollment records for a single student and weaknesses in
the system's ability to track students.  In addition, verification of
student residency remained problematic.  On the basis of the flaws we
identified in the 1996-97 process, we made several recommendations to
DCPS. 

Although DCPS made some changes in its enrollment count process for
the 1997-98 school year in response to our recommendations and plans
to make more, the larger systemic issues appear to remain mostly
uncorrected.  Consequently, fundamental weaknesses still remain in
the enrollment count process, making it vulnerable to inaccuracy and
weakening its credibility.  For example, DCPS staff report that
although an important internal control--duplicate record checks--has
been implemented for SIS, additional internal controls are still
lacking.  Several DCPS enrollment and pupil accounting procedures
continue to increase the possibility of multiple enrollment records
for a single student.  We are concerned that duplicate record checks
alone may not be sufficient to protect the integrity of SIS, given
the many possibilities for error. 

Furthermore, the enrollment count may still include nonresident
students.  More than half (56 percent) of DCPS' students have either
failed to provide the residency verification forms or have provided
no proofs of residency (for example, copies of deeds, rental leases,
utility bills, or vehicle registrations, among others) to accompany
their forms.  We question the appropriateness of including students
who have failed to prove residency in the official count,
particularly students who have not even provided the basic form.  In
addition, because DCPS has not yet monitored and audited residency
verification at the school level, additional problems may exist that
are not yet apparent.  Proposed new rules governing residency will
help DCPS deal with residency issues.  Until these issues are fully
addressed and resolved, however, the accuracy and credibility of the
enrollment count will remain questionable. 

In our more recent discussions with DCPS officials, they acknowledge
that more needs to be done to improve the enrollment count process,
particularly in the areas of further strengthening DCPS' automated
internal controls and addressing the nonresident issue.  They have
expressed concern, however, that we have failed to recognize fully
the improvements DCPS made in the enrollment count process for school
year 1997-98.  We have recognized DCPS' progress but nevertheless
remain concerned about fundamental systemic weaknesses. 


   DCPS' ENROLLMENT COUNT PROCESS
   IN SCHOOL YEAR 1996-97
---------------------------------------------------------- Chapter 0:2

We reported that even though DCPS changed parts of its enrollment
process in school year 1996-97 to address prior criticisms, the
process remained flawed.  Some of the changes, such as the use of an
enrollment card to verify attendance, increased complexity and work
effort but did little to improve the count's credibility.  Because
DCPS counts enrollment by counting enrollment records--not actual
students--accurate records are critical for an accurate count. 
Errors, including multiple enrollment records for a single student,
remained in SIS, but DCPS had only limited mechanisms for correcting
these errors.  For example, although Management Information Services
personnel maintained SIS, they had no authority to correct errors. 
In addition, DCPS' enrollment procedures allowed multiple records to
be entered into SIS for a single student, and its student transfer
process may have allowed a single student to be enrolled in at least
two schools simultaneously.  Furthermore, DCPS' practice of allowing
principals to enroll unlimited out-of-boundary students increased the
possibility of multiple enrollment records for one student. 
Nevertheless, DCPS did not routinely check for duplicate records. 

In addition, DCPS' official enrollment count included categories of
students usually excluded from enrollment counts in other districts
when the counts are used for funding purposes.  For example, DCPS
included in its enrollment count students identified as
tuition-paying nonresidents of the District of Columbia and students
above and below the mandatory age for public education in the
District of Columbia, including Head Start participants,\2
prekindergarten students (age 4), preschool students (age 0 to 3),
and some senior high and special education students aged 20 and
older.\3 In contrast, the three states that we visited reported that
they exclude from enrollment counts used for funding purposes any
student who is above or below mandatory school age or who is fully
funded from other sources.  Furthermore, even though the District of
Columbia Auditor has suggested that students unable to document their
residency be excluded from the official enrollment count, whether
they pay tuition or not, DCPS included these students in its
enrollment count for school year 1996-97. 

During school year 1996-97, District of Columbia schools had some
attractive features.  Elementary schools in the District had free
all-day prekindergarten and kindergarten, and some elementary schools
had before- and after-school programs at low cost.  For example, one
school we visited had before- and after-school care for $25 per week. 
This program extended the school day's hours to accommodate working
parents--the program began at 7 a.m.  and ended at 6 p.m.  In
addition, several high schools had highly regarded academic and
artistic programs; and some high schools had athletic programs that
reportedly attracted scouts from highly rated colleges.  Furthermore,
students could participate in competitive athletic programs until age
19 in the District, compared with age 18 in some nearby
jurisdictions. 

Problems persisted, however, in the critical area of residency
verification.  In school year 1996-97, schools did not always verify
student residency as required by DCPS' own procedures.  Proofs of
residency, when actually obtained, often fell short of DCPS'
standards.  Moreover, central office staff did not consistently track
failures to verify residency.  Finally, school staff and parents
rarely suffered sanctions for failure to comply with the residency
verification requirements. 

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

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

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

Because the enrollment count will become the basis for funding DCPS
and is even now an important factor in developing DCPS' budget and
allocating its resources, we recommended in our report that the
Congress consider directing DCPS to report separately in its annual
reporting of the enrollment count those students

  -- fully funded from other sources, such as Head Start participants
     and tuition-paying nonresidents;

  -- above and below the mandatory age for compulsory public
     education, such as those in prekindergarten or those aged 20 and
     above; and

  -- for whom District residency cannot be confirmed. 

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

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

  -- Clarity, document, and enforce the residency verification
     requirements for students and their parents. 

  -- Institute internal controls in the student information database,
     including database management practices and automatic procedures
     and edits to control database errors. 

  -- Comply with the reporting requirement of the District of
     Columbia School Reform Act of 1995. 

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

In commenting on a draft of our report, DCPS' Chief Executive
Officer/ Superintendent stated that DCPS concurred with our major
findings and recommendations and would correct the identified
weaknesses.  He also acknowledged that the enrollment numbers for
school year 1996-97 are subject to question for the reasons we
cited--especially because the enrollment count credibility hinged
almost entirely on the written verification provided by local
administrators.  He said that no substantial checks and balances, no
aggressive central monitoring, and few routine reports were in place. 
In addition, he said that virtually no administrative sanctions were
applied, indicating that the submitted reports were hardly reviewed. 

The Authority shared DCPS' view that many findings and
recommendations in our report will help to correct what it
characterized as a flawed student enrollment count process.  Its
comments did, however, express concerns about certain aspects of our
report.  The Authority was concerned that we did not discuss the
effects of the Authority's overhaul of DCPS in November 1996.\4 It
also commented that our report did not note that the flawed student
count was one of the issues prompting the Authority to change the
governance structure and management of DCPS.  In the report, we
explained that we did not review the Authority's overhaul of DCPS or
the events and concerns leading to the overhaul. 


--------------------
\2 Head Start has its own funding source. 

\3 The District of Columbia School Reform Act of 1995 requires
separate reporting of some of these groups but does not require that
they be included in aggregate counts. 

\4 For many years, DCPS had been governed by an elected Board of
Education.  In Nov.  1996, the specially appointed Authority declared
a state of emergency in DCPS and transferred DCPS management--until
June 30, 2000--to the Authority's agents, a nine-member specially
appointed Emergency Transitional Education Board of Trustees.  The
Authority also replaced DCPS' superintendent with a Chief Executive
Officer/Superintendent. 


   REPORTED RESPONSES TO OUR
   RECOMMENDATIONS
---------------------------------------------------------- Chapter 0:3

DCPS has made some changes in response to our recommendations.  For
example, it dropped the enrollment card.  DCPS now relies upon other,
more readily collected information, such as a child's grades or work,
as proof that a child has been attending.  DCPS has also strengthened
some mechanisms for correcting SIS errors, such as multiple
enrollment records for a single student.  Staff reported that central
office staff now conduct monthly duplicate record checks.  These
staff then work with the schools to resolve errors.  In addition,
central office staff now have the authority to correct SIS errors
directly.  Schools are also now required to prepare monthly
enrollment reports, signed by the principal, throughout the school
year.  Central office staff review and track these reports.  In
addition, SIS can now track consecutive days of absence for students,
which helps track the implementation of attendance rules.  Finally,
all principals are now required to enter into SIS the residency
status of all continuing as well as new DCPS students.  DCPS
officials believe SIS' residency verification status field also
serves as a safeguard against including both duplicate records and
inactive students in the enrollment count. 

Nonetheless, some DCPS policies and practices that increase the
possibility of multiple records and other SIS errors have not
changed.  For example, DCPS continues allowing schools to enroll,
without restriction, students who live outside school attendance
boundaries.  School data entry staff may still manually override SIS
safeguards against creating multiple records.  In addition, SIS still
lacks adequate safeguards to ensure that it accurately tracks
students when they transfer from one school to another.  SIS' new
residency verification status field will not prevent the creation or
maintenance of duplicate records.  For example, a student might
enroll in one school, filling out all necessary forms required by
that school, including the residency verification form, and decide a
few days later to switch to another school.  Rather than officially
transferring, the student might simply go to this second school and
re-register, submitting another residency verification form as part
of the routine registration paperwork.  If the second school's data
entry staff choose to manually override SIS safeguards, duplicate
records could be created.  Even if a student did not submit a
residency verification form at the second school, the data entry
staff could simply code the SIS residency field to show that no form
had been returned, creating duplicate records. 

Regarding the critical area of residency verification, all principals
must now issue and collect from all students a completed and signed
residency verification form (as well as enter residency verification
status information into SIS as discussed).  Principals are also
encouraged to obtain proofs of residency and attach these to the
forms.  DCPS considers the form alone, however, the only required
proof of residency for the 1997-98 count.  The school district
encouraged but not did not require such supporting proofs to
accompany this form.  A signed form without proofs of residency is
insufficient to prove residency in our opinion.  Such proofs are
necessary to establish that residency requirements have been met. 
Until DCPS students are required to provide substantial proofs of
residency, doubts about this issue will remain. 

To illustrate this point, DCPS states that 83 percent of its
officially enrolled students have provided signed residency
verification forms and therefore have provided certification of
residency.  DCPS staff, however, told us that only 33,852 (44
percent) of the 77,111 students included in the official 1997-98
count have provided both completed residency verification forms and
accompanying proofs of residency.  Another 30,337 (39 percent) have
provided completed forms but no accompanying proofs, and 12,878 (17
percent) have provided no completed forms.  In other words, more than
half (56 percent) of DCPS' students have either failed to provide
basic residency forms or have provided no proofs of residency to
accompany their forms.  (DCPS believes that our characterization of
this situation is misleading and that the great majority of its
students have provided proof of residency.) Furthermore, DCPS staff
told us that the school district has not yet monitored and audited
the schools' residency records but plans to do so shortly. 

DCPS has proposed modifications to the Board of Education's rules
governing residency to strengthen these rules.  The proposed
modifications would strengthen the residency rules in several ways by
stating that at least three proofs of residency "must" be submitted,
rather than "may be" submitted, as current rules state; specifying
and limiting documents acceptable as proofs; eliminating membership
in a church or other local organization operating in the District of
Columbia as an acceptable proof; and strengthening penalties for
students who do not comply.  DCPS staff told us that these proposed
changes are now under consideration by the Authority. 

Regarding our recommendation that the Congress consider directing
DCPS to report separately the enrollment counts of certain groups of
students, the Congress has not yet required that DCPS do this.  DCPS
continues to include these groups in its enrollment count.  For
school year 1997-98, DCPS reports an official count of 77,111
students.\5 This number includes 5,156 preschool and prekindergarten
students who are below mandatory school age in the District of
Columbia.  Some of these students are Head Start participants and are
paid for by Head Start; nevertheless, DCPS counts Head Start
participants as part of its elementary school population.  The count
also includes 18 tuition-paying nonresident students attending DCPS. 
In addition, DCPS staff told us that although the count excludes
adult education students, they did not know whether it includes other
students above the mandatory school age.  Finally, as noted earlier,
the count includes students who have not completed residency
verification. 

In addition to talking to DCPS staff, we talked to staff at the
Authority about whether the Authority has provided for an independent
audit of the 1997-98 enrollment count.  Staff said that the Authority
is in the process of providing for an audit but has not yet awarded a
contract. 


--------------------
\5 DCPS School Year 1997-98 Official Membership, Oct.  30, 1997. 


-------------------------------------------------------- Chapter 0:3.1

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


*** End of document. ***