Audit Report on the Department of Education’s Controls for Ensuring that Its High School Graduates Have Met Graduation Requirements
EXECUTIVE SUMMARY
The objective of this audit was to determine whether the New York City Department of Education (DOE) has adequate controls to ensure that its high school graduates have met graduation requirements.
DOE has approximately 75,000 teachers working in more than 1,800 schools, including over 400 high schools. DOE’s mission is to help students meet grade-level standards in reading, writing, and mathematics and to graduate from high school prepared for careers or for college. About 58,400 students graduated from DOE high schools during the 2012-2013 school year.
High school graduation requirements are set by the New York State Education Department (NYSED). These requirements are determined by the school year in which a student enters the ninth grade (also known as the cohort year), and a student must fulfill them to receive a diploma. DOE can set more rigorous academic expectations than NYSED, but it may not set lower standards.
Most students who entered ninth grade between September 2008 and September 2012 needed to earn a Regents diploma. For such students, Regents diplomas required 44 credits in designated subjects and scores of 65 or higher on five Regents exams in English, Mathematics, Science, United States History, and Global History. Local diplomas (an alternative to a Regents diploma) could be earned by students with Safety Net provisions, such as Individualized Education Programs (IEPs) or Section 504 Accommodation Plans (504 plans). Local diplomas also required 44 credits in designated subjects, but students could earn lower scores on the Regents exams (i.e., 55 to 64).
DOE’s Office of Academic Policy and Systems (OAPS), in the Division of Teaching and Learning, oversees the high school graduation process.
OAPS is responsible for tracking and sharing New York State academic policies with schools. OAPS expects high school principals to maintain procedures and systems for certifying that students have met all graduation requirements and are eligible for diplomas.
DOE uses two computer systems to track students through the high school graduation process: (1) Automate the Schools (ATS)-a system that collects student demographic and biographical information, as well as final graduation data (e.g., graduation date, type of diploma); and (2) Student Transcript and Academic Reporting System (STARS)-a system that collects information on students’ credits, grades, and Regents exam scores. STARS helps high schools monitor the status of a student’s course credits and Regents exams.
Audit Findings and Conclusions
The audit found weaknesses in DOE’s controls intended to ensure that its high school graduates have met graduation requirements. We also found that DOE has taken steps to improve its processes. Among those steps, DOE’s central office has provided specific academic guidance to high schools in its February 2012 High School Academic Policy Reference Guide. In its March 26, 2012 Course Code Directory – High School, DOE clarified the appropriate course codes to use on students’ transcripts. In addition, DOE has provided some evidence that it reviews transcript updates and school graduation data, identifies concerns, and works with the schools to resolve them.
However, DOE still does not have sufficient controls to ensure that high school graduates have actually fulfilled all of the necessary requirements. Our audit found transcripts for graduated students that failed to provide adequate information to establish the bases for the students having been allowed to graduate. In many instances, we found schools applied override codes that permitted students to graduate, but provided little or no justification for their use of the overrides. Underlying these weaknesses, we found that DOE does not regularly review a sample of STARS transcripts to ensure that graduation requirements have been properly fulfilled; it does not regularly review a sample of graduation status overrides in ATS to ensure that the overrides are appropriate; it does not ensure that graduation status overrides and transcript updates are properly justified and approved; and it does not effectively ensure that access to ATS and STARS is revoked for former school employees upon the termination of their employment.
Audit Recommendations
To address these issues, this report makes a total of 21 recommendations, including the following:
- DOE should regularly review samples of student transcripts and graduation status overrides to ensure that its schools are properly enforcing graduation requirements.
- DOE should require that a graduation status override entered in ATS be approved by a principal or assistant principal.
- DOE should modify STARS to require that transcript updates be approved by higher-level officials, such as an assistant principal or the principal of the school.
- DOE should ensure that the schools maintain sufficient documentation to support their transcript updates.
- DOE should ensure that the schools inform DOE central whenever individuals no longer require their current level of access or any access to ATS or STARS.
- DOE should require schools to periodically review the lists of active ATS and STARS users at their schools to determine whether the lists are accurate.
- DOE should ensure that graduation lists it receives from NYSED for review are examined for anomalies or discrepancies.
Agency Response
In their response, DOE officials agreed with most of the audit’s findings and with 17 of the 21 recommendations. Officials disagreed with the recommendations relating to the provision of more detailed justifications for graduation status overrides, the approval of transcript updates prepared by principals, and the monitoring of user access to ATS and STARS. Officials also asked for clarification of one other recommendation, which is provided in the body of the report.