on the audit of Temporary Emergency Impact Aid for Displaced Students

 There's nothing quite like a front page article to focus the mind...

Let me observe that this was reported as long as two weeks ago in the Boston Globe, and then last week by both NEPM and WBUR. I've been a little distracted, and administration did not share anything with the Worcester School Committee until last night, so I haven't delved into this until now. Mea culpa

I've posted the audit itself online here, though the federal posting is here. You can also track the degree to which the Department has resolved the findings of the audit here. 

First, what are we talking about? If you cast your mind back to 2017, you might remember Hurricane Maria? And then fires in California? There was federal aid that came in, as families in some cases fled and in some cases sent their children away from the disaster areas. Massachusetts received $15.5M, which was (per the audit) the fifth largest award to any state; of that, Worcester and Springfield received (together) almost a third of the state award (Worcester: $2M; Springfield: $3.1M)

This is a federal audit of Massachusetts' expenditure and tracking of those funds. 

Like most federal grant funds, this Temporary Emergency Impact Aid for Displaced Students came from the federal government to the state to disburse to districts. The audit then--and this is really important!--is actually of the state Department of Elementary and Secondary Education, with the two districts involved in this audit, Worcester and Springfield, being what was sampled (as they were the biggest recipients of the aid). 

The audit--and my compliments to the Office of the Inspector General on this!--is readable, so if this is at all of interest, do just go read the audit. 

What was found? Well, the Globe headline was "slams local districts and Mass. education department’s oversight of emergency aid," so nothing good, let's say. The audit has two main "findings," as they're called (this is my rephrasing of them): 

1. Massachusetts didn't make sure that the student counts were accurate and complete and that districts spent the money correctly;
2. Massachusetts didn't make sure that districts used the funds for students with disabilities for those students and didn't make sure that employees paid with these funds were actually working with displaced students. 

Now, again, there's actually two layers to these findings: the audit is of DESE, but some of the findings are about district practice, as well. 

On the first finding, part of what the audit takes issue with is DESE decided to use displaced student data from a state aid program, rather than have districts replicate the count. On sampling student data, the audit found some students who "were inaccurately counted as displaced," either because they'd been enrolled prior to the year in question or because there was not sufficient documentation to support their status as displaced. From the Inspector General's perspective, this very much is not a district level issue only; there are extensive requirements of the states to ensure student counts like this are accurate. Massachusetts, per the audit, did not verify data, did not provide an opportunity for districts to check data, and did not monitor the districts (on this last, the state argued, as MGL ch. 15, sec. 55A requires that the state not do multiple comprehensive audits or reviews within a 9 month period).

On the second finding, some of the aid provided was specifically for students with disabilities, yet the state did not separate out which aid was specific to that, so districts could not ensure that funding went to providing services to those students. Also, employees who may have been paid with this aid were not all at schools serving displaced students. 

While the articles made clear that there was no expectation at this time that funds should be repaid, both the audit itself and the open recommendations on the Inspector General's site make it clear that the expectation is that either the funds would be repaid or the state would (effectively) show that they didn't need to be. 

The part of the report that I think is actually most damning is that the draft was provided, as is customary, to the Department last June. The state only responded:

it will work with the two LEAs (Springfield and Worcester) to resolve issues noted in the draft report and will establish alternative procedures that are more conductive for future funding opportunities that occur after the close of the fiscal year to ensure that all students claimed are eligible and that all grant data requirements are met.

Among the (several) requirements of the audit, however, were that the state review the other 67 districts that received funds under this grant to see if they likewise have such issues (as one might expect!). The state has made no such provision; nor has it responded to most of the other findings.

From a Worcester perspective, Superintendent Binienda sent the Worcester School Committee the audit on Tuesday evening. We had not received any earlier notification that the district was part of a federal audit on these funds. Moreover, in Worcester currently, the grants department is not overseen by the finance office; it is under the Deputy Superintendent. The School Committee has expressed concerns about this managerial decision several times, most recently at some length during the last budget deliberation. The superintendent nonetheless has maintained this arrangement. 
The School Committee has been told that the administration is meeting with the Department on Friday. I've asked that we be given an update after that meeting, as there may be additional steps necessary in terms of policy and oversight.