Audit Report on the Department of Education’s Efforts to Monitor and Address School Attendance of Homeless Children Residing in Shelters
March 15, 2018 | MG16-098A
The New York City (City) Department of Education (DOE) is the largest school district in the United States, serving 1.1 million students in over 1,800 schools. One of DOE’s responsibilities is to track the attendance of students and to follow up appropriately with absent students and their families. The need for adequate follow-up is especially important for chronically absent students and for students whose pattern of absences appears to be approaching a chronic level, defined by DOE to occur when a student’s attendance rate is less than 90 percent. Chancellor’s Regulation A-210 mandates that schools maintain a system for recognizing patterns of student absence and that they implement specific intervention strategies to reduce the number of students who are chronically absent.
Responsibility for tracking school attendance rests with the individual schools and their principals. They are given specific requirements, overall guidance, and support in their efforts by, among other things: specific Chancellor’s Regulations; the DOE Office of Safety and Youth Development (OSYD); and borough-based Field Support Centers. OSYD’s responsibilities include supporting students’ well-being, academic achievement, and social growth through, among other things, establishing and implementing integrated policies and procedures. The Field Support Centers are independent of OSYD but work with that office and with individual schools to provide integrated supports to schools. The Field Support Centers are specifically responsible for providing assistance to help ensure that schools’ attendance program requirements are met. Their responsibilities include assisting schools in the development of Attendance Plans that allow for the effective implementation of attendance tracking, outreach, follow-up and support services and reviewing such plans.
Incidences of poor school attendance have been found to be more prevalent among students who reside in homeless shelters than the general student population. In part to address this national phenomena, the federal McKinney-Vento Homeless Assistance Act of 2001 (the McKinney-Vento Act) mandates that homeless children be guaranteed equal access to the same free appropriate public education provided to children who are permanently housed within the community. DOE has assigned the responsibility for meeting the requirements of the McKinney-Vento Act and other related policies and procedures to its Students in Temporary Housing (STH) unit, which is a component of OSYD. In order to achieve the goals of the McKinney-Vento Act, every community school district assigns Family Assistants (DOE employees stationed at shelters) and assigned to work with the homeless families and monitor school attendance of the children in those families.
The City Department of Homeless Services (DHS) is responsible for providing short-term, emergency shelter for individuals and families who have no other available housing options. DOE and DHS have each established their own procedures and requirements intended to ensure that school-aged children (Pre-Kindergarten through grade 12), ages 4-21, residing in City shelters attend school regularly and that outreach and intervention is conducted when necessary.
This audit focused on DOE’s efforts to monitor, track and help ensure school attendance by homeless children residing in shelters. Specifically, the objective of this audit was to determine whether DOE conducted adequate outreach and provided sufficient oversight of the attendance of students residing in DHS-operated homeless shelters.
Audit Findings and Conclusions
DOE does not engage in adequate outreach or have sufficient oversight of efforts made to track and monitor the attendance of students residing in temporary housing who are chronically absent from school, particularly those residing in DHS-operated homeless shelters. While DOE has established multiple protocols related to student absences that central staff and individual school employees are required to follow, it does not have adequate oversight mechanisms to ensure that these protocols are followed. In a number of instances in our audit sample, we found that they were not adhered to. Since students who reside in temporary housing are known to have higher rates of absenteeism than the permanently-housed student population, DOE’s oversight weaknesses could particularly increase the safety and welfare risks to this already vulnerable group of children.
For our sample of 73 students who were identified by DOE as having resided in DHS homeless shelters during the 2015-2016 School Year and who, based on data provided by DOE, we identified as being chronically absent, our analysis of activity by individual schools revealed:
- No evidence that schools conducted outreach efforts for 25 students (34 percent) who were chronically absent (12 students had no evidence of outreach, and 13 students had outreach efforts that were not specific to absences). In addition, there was no evidence of outreach efforts for 50 students (68 percent) with occurrences of latenesses.
- No evidence that schools conducted outreach on the first day of a student’s absence in 92 percent of the instances related to absences where such outreach was required.
- No evidence that schools conducted outreach for 87 percent of the absences reported for our sampled students and for 94 percent of the latenesses reviewed.
In addition, DOE did not provide evidence that Family Assistants who work in the shelters themselves conducted any outreach related to absences or latenesses for 54 percent of the sampled students. We believe that the Family Assistant outreach failures we found resulted in large part from the fact that DOE has not dedicated sufficient staff necessary to adequately oversee the students.
We also found deficiencies in schools’ response to OSYD questionnaires regarding the schools’ individual 2015-2016 School Year Attendance Plans. In the absence of adequate controls to ensure that schools have Attendance Plans that conform to DOE regulations, there is an increased risk that they will not effectively assist students with attendance issues.
To address the issues raised by this audit, we make 12 recommendations, including the following:
- DOE should enhance its policies and procedures as needed to ensure that school officials immediately make the required outreach and intervention efforts and that those efforts are adequately documented, in accordance with the Chancellor Regulations.
- DOE should ensure that those charged with the oversight responsibilities for student attendance are familiar with their responsibilities.
- DOE should amend its current process and ensure that all students’ absence histories are fully recognized within the Automate the Schools (ATS) system, absence patterns are properly identified, and Form 407 Referrals are generated, regardless of whether or not students have transferred from other schools.
- DOE should conduct a study to determine the adequacy of its current caseloads for Family Assistants to determine if it has sufficient staff levels to enable the Family Assistants to effectively fulfill their job responsibilities.
- Based on the results of the study referred to above, DOE should consider using the findings from the study as justification for increasing the number of Family Assistants overseeing the shelters through reassignments of existing staff and/or by seeking additional funding from the City’s Office of Management and Budget to hire additional Family Assistants.
- DOE should establish procedures with clear roles and responsibilities to ensure the ongoing assessment and evaluation of school-based attendance activities, including student monitoring by Superintendents and outreach efforts by responsible parties, so that students with poor attendance are identified and receive necessary outreach and intervention.
DOE stated that it agreed with four of the 11 recommendations directed to the agency and partially agreed with another four. However, to the extent that DOE stated that it agreed or partially agreed with five of the audit recommendations, it qualified that “agreement” by stating that it “agrees with the recommendation in that it is current practice.” (Emphasis added.) Thus, DOE effectively rejected the auditors’ recommendation that current practice should be improved in each of these instances. Of the remaining three recommendations, DOE expressly disagreed with one and did not specifically address two. DOE also expressly disagreed with a number of the audit findings. We address these areas of disagreement in detail in the body of this report. After carefully reviewing DOE’s arguments, we find no basis to alter any of the audit’s findings.
In its response, DHS agreed to implement the one recommendation directed to the agency.
 Each school’s Attendance Plan is created through its response to a questionnaire that the school must submit to OSYD. Among other things, in those questionnaires the schools must identify their policies and procedures regarding attendance.
 DHS contracts with shelter providers to house homeless families and to provide services. DHS is responsible for ensuring compliance with the contracts. Case Managers, who are shelter employees, must comply with DHS requirements in working with the families and ensuring that school-age children attend school.
 Matters related to DHS’s provision of support and outreach to homeless families with children were covered in a separate audit entitled, “Audit Report on the Controls of the Department of Homeless Services over the Shelter Placement and the Provision of Services to Families with Children” (#MG14-088A) issued by this office on December 18, 2015.
 According to the list provided by DOE, our initial sample of 73 students resided in shelter during the 2015-2016 School Year. However, further analysis revealed that 15 of the 73 sampled students did not reside in shelter during this period.
 The STH Family Assistants’ outreach efforts are separate and distinct from the outreach efforts made by the schools.