June 14, 2005

**Control Number ED-OIG/A07E0027**

Judy Jeffery, Interim Director

Division of Early Childhood, Elementary and Secondary Education

Iowa Department of Education

Grimes State Office Building

400 East 14^th^ Street

Des Moines, IA 50319-0146

Dear Ms. Jeffery:

This Final Audit Report, entitled *Iowa Department of Education's
Compliance with the Unsafe Schools Choice Option Provision*, presents
the results of our audit. The purpose of the audit was to determine
whether (1) Iowa's Unsafe School Choice Option (USCO) policy complied
with Title IX, Part E, Subpart 2, § 9532 of the Elementary and Secondary
Education Act, as amended by the No Child Left Behind Act of 2001
(ESEA), and applicable U.S. Department of Education (Department)
guidance; and (2) the Iowa Department of Education (IDE) adequately
implemented the USCO policy. Our audit covered school years 2002-2003
and 2003‑2004.

IDE's USCO policy generally complied with § 9532 of the ESEA and the
Department's guidance. However, IDE has not adequately implemented
Iowa's USCO policy because it did not ensure the policy was implemented
at the local level. Two of the three Iowa local educational agencies
(LEA) covered by our audit did not report all USCO incidents with 10-day
suspensions (See Finding No. 1). In addition, the three Iowa LEAs
covered by our audit did not address the USCO transfer options (See
Finding No. 2).

In the OTHER MATTER section of this report, we note that IDE might not
receive sufficient information to provide reasonable assurance that it
identified all unsafe schools and appropriately made persistently
dangerous school (PDS) designations. We discuss suggestions presented in
the Department's guidance that we encourage IDE to consider in future
reviews of Iowa's USCO policy.

In response to the draft of this audit report, IDE did not dispute the
facts presented in Finding No. 1, accepted the results presented in
Finding No. 2, and did not comment on the information presented in the
OTHER MATTER section of the report. IDE agreed to implement five of the
six recommendations presented in the draft audit report. IDE commented
on recommendation 1.3, stating that it agreed that "information required
for USCO should be accurately maintained by school districts and
accurately reported to the Iowa Department of Education." However, IDE
did not agree with the recommendation to request a verification from
districts that they reported all ten-day suspensions and accurately
reported punishments during the 2002-03 and 2003-04 school years. IDE
stated that, because we noted that none of the schools would have met
the definition of a PDS, it would be better to ensure that future
reporting is conducted in an accurate and timely manner. Based on IDE's
comments, we revised recommendation 1.3. We made no other changes to the
report.

+-----------------------------------------------------------------------+
| #                                                                     |
|                                                                       |
| # BACKGROUND                                                          |
+-----------------------------------------------------------------------+

The USCO in § 9532 requires that states receiving funds under the ESEA
establish and implement a statewide policy requiring that students
attending a persistently dangerous public school, or students who become
victims of violent criminal offenses while on the grounds of a public
school they attend, be allowed to attend a safe public school. The
Department issued *Unsafe School Choice Option Non-Regulatory Guidance*
in May 2004.(This guidance was issued in draft form in July 2002.)

IDE determined that none of Iowa's schools met the State's definition of
"persistently dangerous" in school years 2002-2003 and 2003-2004. Under
Iowa\'s USCO policy, a public elementary or secondary school is
considered to be \"persistently dangerous\" if, in each of three
consecutive years, all of the following conditions were met:

-   The school had violence-related, long-term suspensions or expulsions
    -- ten days or more in length -- for more than one percent of the
    student population;

-   The school had two or more students expelled for violating the
    federal or state gun-free school laws; and

-   The school had one percent of the enrolled student population or
    five students, whichever is greater, who exercised the individual
    student option.[^1]

The violent criminal offenses delineated in the policy by the pertinent
Iowa Education Codes are 1) a forcible felony; 2) offenses, excluding
simple misdemeanors, involving physical assault; 3) offenses, excluding
simple misdemeanors, involving sexual assault;

4\) kidnapping; 5) first and secondary degree robbery and extortion; 6)
first degree arson;

7\) use of incendiary or explosive devices such as bombs; 8) criminal
gang activity; and

9\) carrying and or using a weapon.

According to IDE officials, IDE developed its definition of a PDS in
consultation with the School Administrators of Iowa, the Iowa
Association of School Boards, the State Board of Education, and staff
from LEAs. IDE obtained input on criteria to use for its definition from
state agencies such as the Department of Human Services, the Department
of Public Health, the Division of Criminal and Juvenile Justice
Planning, the Office of Drug Control Policy, and the Governor's office
through the Iowa Collaboration for Youth Development. Because IDE did
not collect expulsion or suspension data from LEAs prior to the USCO,
its PDS criteria included information already available in its federal
Gun-Free Schools Act reports, other data collected from the LEAs, and
discussions with LEAs. In addition, IDE examined policies developed by
states with similar populations and heavily rural schools and held
discussions with representatives from eight LEAs (called the Urban 8
Network). The State's Safe and Drug-Free Schools Advisory Committee
reviewed and commented on IDE's initial draft of the definition.

Because LEAs annually report information, including expulsions for
weapons offenses, under the federal Gun-Free Schools Act using the Basic
Educational Data Survey (BEDS), IDE used the federal Gun Free Schools
Act report as the initial screening for determining PDS. Had IDE found a
school reporting two or more expulsions in three consecutive years, it
would have contacted the school for additional data that would allow IDE
to assess the school on the remaining criteria in IDE's definition of a
PDS. For the 2003-2004 school year, IDE began collecting additional data
on schools. The additional data included (1) violence-related, long-term
suspensions or expulsions; (2) federal Gun-Free Schools Act expulsions;
and (3) the number of students who transferred under Iowa's USCO policy.
Although LEAs and schools provided the additional data using BEDS for
the 2003-2004 school year, IDE is implementing a new system -- called
Project Easier -- to facilitate USCO reporting. Beginning with the
2004-2005 school year, LEAs will report annually on all USCO criteria
through the State\'s new system.

+-----------------------------------------------------------------------+
| #                                                                     |
|                                                                       |
| # AUDIT RESULTS                                                       |
+-----------------------------------------------------------------------+

**FINDING NO. 1 -- LEAs Did Not Report All USCO Incidents Resulting in
10-Day Suspensions or Expulsions**

Pursuant to Iowa state law, Chapter 11, Unsafe School Choice Option,
LEAs must report data in a manner prescribed by the State's department
of education. IDE instructed LEAs to report the number of
violence-related, long-term suspensions or expulsions. At each of three
LEAs, we reviewed student suspension and expulsion files for three
schools. Two of the three LEAs reviewed did not report all of the USCO
incidents that resulted in 10-day suspensions.

#### Des Moines Independent Community School District

Des Moines reported 20 USCO incidents at Brody Middle School for school
year 2002‑2003, but did not report 1 other USCO incident even though the
student received a 10-day suspension for the offense (a second fighting
incident). The district incorrectly recorded the punishment as a 1-day
suspension.

Des Moines reported 6 USCO incidents at Brody Middle School for school
year 2003-2004, but did not report 1 other USCO incident (possession of
a dart gun and darts) even though the student received a 10-day
suspension for the offense. The district incorrectly recorded the
punishment as a 1-day suspension.

#### Davenport Community School District

Davenport reported 11 USCO incidents at Sudlow Intermediate School for
school year 2003-2004, but did not report 2 other USCO incidents---1 for
assaulting a teacher and 1 for fighting with another student---even
though the students received 10-day suspensions for the offenses.

Davenport reported 4 USCO incidents at North High School for school year
2003-2004, but did not report 7 other USCO incidents---3 for possession
of knives and 4 for assault/fighting---even though the students received
10-day suspensions for the offenses.

### IDE's and LEAs' Internal Control Could Be Strengthened

None of the schools reviewed would have met Iowa's criteria for a PDS
designation. However, at the time of our audit, IDE had not (1)
initiated any monitoring activities to assess LEA compliance with Iowa's
USCO policy, (2) evaluated school procedures for collecting and
reporting USCO incidents, and (3) verified the accuracy of reported
data.

Schools and LEAs need to have adequate procedures for classifying,
documenting, and reporting incidents. Otherwise, IDE cannot be
reasonably assured that districts are providing reliable data for making
PDS determinations. If dangerous schools are not identified as PDS,
parents will not be notified and offered the option to transfer their
children to a safer school.

**Recommendations**

We recommend that the Deputy Under Secretary for Safe and Drug-Free
Schools require IDE to:

1.  Develop and implement policies and procedures for monitoring LEA
    compliance with Iowa's USCO policy;

2.  Evaluate school procedures for collecting information on and
    reporting USCO incidents; and

3.  Ensure that, for all future reporting periods, Iowa LEAs (a) report
    all 10-day suspensions for USCO offenses to IDE and (b) accurately
    record punishments for USCO offenses.

**FINDING NO. 2 -- LEAs Did Not Offer the USCO Transfer Option**

None of the three LEAs reviewed offered victims of violent criminal
offenses the option to transfer to a safe public school. In addition,
the LEAs might not have accurately reported the number of victims
transferring due to violence. As a result, victims of violent crimes may
have remained in an unsafe environment, and IDE might not have received
the information necessary to make an assessment of PDS.

Pursuant to § 9532 of the ESEA, if a student becomes the victim of a
violent criminal offense at a school, the LEA must allow the student to
transfer to another public school. The transfer is optional - the
student is not required to transfer but the offer for such a move must
be made. In addition, Iowa's USCO policy, Chapter 11, states

> \[Subrule\] **281---11.4 Individual Student Option.** Any student who
> becomes a victim of a violent criminal offense shall, to the extent
> feasible, be permitted to transfer to another school within the
> district. For purposes of the subrule, a victim of a violent criminal
> offense is a student who is physically injured or threatened with
> physical injury as a result of the commission of one or more of the
> following crimes against the student while in the school building or
> on the grounds of the student's attendance center.

The LEAs did not offer victims of violent criminal offenses the transfer
option because none of the three had developed policies or procedures
specific to USCO for (1) offering victims the transfer option and (2)
tracking the number of victims transferring under the option. Iowa has
an open enrollment policy. Therefore, victims of violent criminal
offenses already are afforded the opportunity to transfer.

At the time of our audit, IDE had not initiated any monitoring
activities to assess LEAs' compliance with Iowa's policy for offering
the victims of violent criminal offenses the transfer option. However,
IDE stated that it recently implemented an individual student record
data management system, which provides the necessary procedures to track
transfers resulting from USCO incidents. IDE added that it provided
districts with information about their obligations for parent
notification during the process of adopting its USCO policy. In
addition, IDE stated that it plans to work with the Iowa Association of
School Boards (IASB) to ensure that all LEAs are well-informed of their
obligations for parent notification and will monitor the success of this
effort.

**Recommendations**

We recommend that the Deputy Under Secretary for Safe and Drug-Free
Schools require IDE to

2.1 Monitor LEA compliance with Iowa's USCO policy, including (a)
reviewing LEAs' transfer policies; (b) confirming that students who were
victims of violent crimes were provided the option to transfer to a safe
school; and (c) verifying that documentation was retained showing that
victims' parents were notified of the USCO transfer option and whether a
transfer was requested and completed;

2.  Require LEAs to include the transfer option in their written
    policies; and

3.  Require LEAs to retain documentation showing that victims' parents
    were notified of the USCO transfer option and whether a transfer was
    requested and completed.

**OTHER MATTER**

IDE did not have sufficient information to ensure that it identified
unsafe schools and appropriately made PDS designations. Iowa law
requires LEAs to report incidents in a manner prescribed by IDE. IDE
directed the LEAs to report incidents resulting in 10-day or more
suspensions or expulsions. However, LEAs' suspension policies are not
sufficient for determining a PDS and not all violent criminal offenses
occurring at the schools resulted in the students receiving long-term
suspensions or expulsions.

To be designated a PDS under Iowa law, a school must have had
violence-related, long-term suspensions or expulsions for more than one
percent of the student population for three consecutive years. Long-term
suspensions or expulsions are defined as being ten days or more.
Although LEAs expel students under the federal Gun-Free Act, the LEAs
reviewed generally did not suspend students for 10 days or more because
Iowa's emphasis is on preventing violence and correcting behavior. For
serious incidents, two of the reviewed LEAs generally transferred the
individuals committing the offenses to alternative educational
facilities rather than give them long-term suspensions.

### Schools Did Not Report All Incidents of Violent Criminal Offenses

### or Discipline Students in a Consistent Manner

At each of three LEAs, we reviewed student suspension and expulsion
files for three schools. None of the LEAs reported all violent criminal
offenses[^2] that occurred at their schools during the 2002-2003 and
2003-2004 school years because the incidents did not result in long-term
suspensions or expulsions.

Table I

+-----------------------+-----------------------+----------------------+
| ######### Unreported  |                       |                      |
| Incidents of Violent  |                       |                      |
| Criminal Offenses[^3] |                       |                      |
+-----------------------+-----------------------+----------------------+
| **Davenport Community | **Des Moines          | **Cedar Rapids       |
| School District**     | Independent Community | Community School     |
|                       | School District**     | District**           |
+-----------------------+-----------------------+----------------------+
| North High School     | Roosevelt High School | Kennedy High School  |
|                       |                       |                      |
| 2002-2003 -- 1        | > 2002-2003 -- 11     | > 2002-2003 -- 12    |
|                       | >                     | >                    |
| > 2003-2004 -- 10     | > 2003-2004 -- 9      | > 2003-2004 -- 11    |
+-----------------------+-----------------------+----------------------+
| Sudlow Intermediate   | Brody Middle School   | McKinley Middle      |
| School                |                       | School               |
|                       | > 2002-2003 -- 10     |                      |
| > 2002-2003 -- 13     | >                     | > 2002-2003 -- 18    |
| >                     | > 2003-2004 -- 31     | >                    |
| > 2003-2004 -- 18     |                       | > 2003-2004 -- 22    |
+-----------------------+-----------------------+----------------------+
| Buffalo Elementary    | Moulton Elementary    | Hoover Elementary    |
| School                | School                | School               |
|                       |                       |                      |
| > 2002-2003 -- 14     | > 2002-2003 -- 13     | > 2002-2003 -- None  |
| >                     | >                     | >                    |
| > 2003-2004 -- 7      | > 2003-2004 -- 28     | > 2003-2004 -- 6     |
+-----------------------+-----------------------+----------------------+

Examples of the violent criminal offenses that the LEAs did not report
are

-   weapons violations

```{=html}
<!-- -->
```
-   assaults with serious injuries to the victims

-   threats to kill other students,

-   threats to kill teachers

-   threats to harm other students with weapons

-   threats to bomb the school

-   incidents of violent and disruptive behavior

### Better Guidance on Classifying Incidents and Disciplining Students Needed

At the time of our audit, IDE had not provided supplemental guidance to
the LEAs specifying when incidents and physical injuries should be
classified as violent criminal offenses. Schools and LEAs need clear
guidance so they classify incidents as violent criminal offenses and
discipline the students who commit such offenses in a consistent manner.
Otherwise, IDE cannot be reasonably assured that districts are providing
reliable data for making PDS determinations. If incidents are classified
and reported in a consistent manner, IDE will have better information to
use in analyzing schools and determining whether a school should be
considered a PDS.

According to IDE, the LEAs' reporting for the school years reviewed was
in alignment with State policy. Iowa's policy focuses on the number of
long-term suspensions and expulsions for the violations cited. At the
time of our audit, IDE did not ask LEAs to report the number of
incidents of violent criminal offenses under its policy. In addition,
local school districts were not prohibited from suspending students for
more than ten (10) days in a school year. Consistent with the State's
emphasis on prevention and proactive approaches, many districts that
have the resources offer students programs that are alternatives to
suspension and expulsion. IDE emphasized that its goal is for
weapons-free, safe school environments for all students in Iowa and
contends that the provisions of the State's definition would identify
PDS consistent with the federal intent to identify "persistently"
dangerous schools.

LEAs may not be prohibited from suspending students for 10 days or more.
However, we found inconsistencies in the disciplinary actions schools
took for incidents with the same or similar classifications.

The Department's guidance provided states with several suggestions for
consideration when establishing their definitions of "persistently
dangerous." Among other things, the Department suggested that states use
data that relate to incidents even when an offender is not apprehended
and subsequently disciplined (for example, suspended or expelled).

We encourage IDE to consider the Department's suggestions in any reviews
that it might conduct in the future of the State's USCO policy to ensure
that Iowa's parents are provided with both the knowledge and option to
keep their children safe. We also suggest that IDE (a) issue guidance to
LEAs, specifying when incidents should be reported as USCO violations
and indicating appropriate disciplinary action given the seriousness of
the offense; and (b) confirm that LEAs have taken appropriate corrective
actions to ensure that all USCO incidents are accurately and
consistently reported to IDE.

+-----------------------------------------------------------------------+
| # OBJECTIVES, SCOPE, AND METHODOLOGY                                  |
+-----------------------------------------------------------------------+

Our audit objectives were to determine whether (1) Iowa's USCO policy
complied with applicable law and Department guidance; and (2) IDE
adequately implemented the USCO policy. The audit covered school years
2002-2003 and 2003-2004.

To accomplish our objectives, we interviewed IDE staff responsible for
the development and implementation of Iowa's USCO policy and reviewed
related documents. At three judgmentally selected LEAs, we interviewed
administrative staff to determine how Iowa's USCO policy was implemented
at the local level; visited three public schools within each LEA and
interviewed school administrators to determine if the schools complied
with the USCO policy; reviewed documents related to student incidents to
determine whether incidents were correctly reported to IDE; and reviewed
written policies to determine if the policies addressed the USCO
transfer option and that students who were the victims of violent crimes
were offered transfers to safe public schools. We were unable to review
all requests for transfers from the selected schools to identify victim
transfer requests because the districts and schools did not maintain
sufficient data.

We selected the three LEAs using statewide uniform crime reporting
statistics in conjunction with the statewide allocation of funds for
safe and drug free communities. We identified the five counties that had
the highest crime indexes and the highest allocation of funds for the
2003-2004 school year and selected the top three for review. For each
LEA, we randomly selected one high school, one middle school, and one
elementary school. **Table II** shows the schools reviewed for each LEA
and the reported USCO incidents for each school.

Table II

+-----------------------+-----------------------+----------------------+
| ######### Report      |                       |                      |
| ed USCO Incidents[^4] |                       |                      |
+-----------------------+-----------------------+----------------------+
| **Davenport Community | **Des Moines          | **Cedar Rapids       |
| School District**     | Independent Community | Community School     |
|                       | School District**     | District**           |
+-----------------------+-----------------------+----------------------+
| North High School     | Roosevelt High School | Kennedy High School  |
|                       |                       |                      |
| 2002-2003 -- 21       | > 2002-2003 -- 48     | > 2002-2003 -- None  |
|                       | >                     | >                    |
| > 2003-2004 -- 4      | > 2003-2004 -- 38     | > 2003-2004 -- 1     |
+-----------------------+-----------------------+----------------------+
| Sudlow Intermediate   | Brody Middle School   | McKinley Middle      |
| School                |                       | School               |
|                       | > 2002-2003 -- 20     |                      |
| > 2002-2003 -- 11     | >                     | > 2002-2003 -- None  |
| >                     | > 2003-2004 -- 6      | >                    |
| > 2003-2004 -- 11     |                       | > 2003-2004 -- None  |
+-----------------------+-----------------------+----------------------+
| Buffalo Elementary    | Moulton Elementary    | Hoover Elementary    |
| School                | School                | School               |
|                       |                       |                      |
| > 2002-2003 -- None   | > 2002-2003 -- None   | > 2002-2003 -- None  |
| >                     | >                     | >                    |
| > 2003-2004 -- None   | > 2003-2004 -- None   | > 2003-2004 -- None  |
+-----------------------+-----------------------+----------------------+

We performed our fieldwork at IDE's offices in Des Moines, Iowa during
August and October 2004 and at the selected LEAs and schools from August
through December 2004. We discussed the results of our audit with IDE
officials on February 15, 2005. Our audit was performed in accordance
with generally accepted government auditing standards appropriate for
the scope of audit described above.

+-----------------------------------------------------------------------+
| #                                                                     |
|                                                                       |
| # STATEMENT ON INTERNAL CONTROL                                       |
+-----------------------------------------------------------------------+

As part of our review, we assessed the system of internal control
applicable to IDE's and the selected LEAs' implementation of Iowa's USCO
policy. For the purpose of this report, we categorized significant
control into the following categories:

-   PDS policy formulation and implementation.

-   IDE and LEA data collection and reporting.

-   IDE certification of compliance with Section 9532 of the ESEA.

-   LEA implementation of the USCO transfer option.

Because of inherent limitations, a study and evaluation made for the
limited purpose described above would not necessarily disclose all
material weaknesses in IDE's and the LEAs' systems of internal control.
However, our assessment disclosed significant internal control
weaknesses that could adversely affect the implementation of Iowa's USCO
policy at the local level. Specifically, IDE had not (1) initiated any
monitoring activities to assess LEA compliance with Iowa's USCO policy,
(2) evaluated school procedures for collecting and reporting USCO
incidents, and (3) verified the accuracy of reported data. In addition,
LEAs lacked adequate procedures and/or documentation for implementation
of the USCO transfer option. These weaknesses and their impact are
discussed in the AUDIT RESULTS section of this report.

+-----------------------------------------------------------------------+
| #                                                                     |
|                                                                       |
| # ADMINISTRATIVE MATTERS                                              |
+-----------------------------------------------------------------------+

Statements that managerial practices need improvements, as well as other
conclusions and recommendations in this report, represent the opinions
of the Office of Inspector General. Determinations of corrective action
to be taken will be made by the appropriate U.S. Department of Education
officials.

If you have any additional comments or information that you believe may
have a bearing on the resolution of this audit, you should send them
directly to the following Education Department officials, who will
consider them before taking final Departmental action on the audit:

Deborah A. Price

Assistant Deputy Secretary

Office of Safe and Drug-Free Schools

Room 1E110A

Federal Building No. 6

400 Maryland Avenue, S.W.

Washington, D.C. 20202

It is the policy of the U.S. Department of Education to expedite the
resolution of audits by initiating timely action on the finding and
recommendations contained in audit reports. Therefore, receipt of your
comments within 30 days would be appreciated.

In accordance with Freedom of Information Act (5 U.S.C. §552), reports
issued by the Office of Inspector General are available to members of
the press and general public to the extent information contained therein
is not subject to exemptions in the Act.

We appreciate the cooperation provided to us during our audit. Should
you have any questions concerning this report, please call me at (312)
886-6503.

> Sincerely,
>
> /s/
>
> Richard J. Dowd
>
> Regional Inspector General for Audit

May 13, 2005

Richard J. Dowd

Regional Inspector General for Audit

U.S. Department of Education

111 N. Canal Street

Chicago, Illinois 60606-7297

Dear Mr. Dowd:

This letter is in response to the Draft Audit Report, entitled *Iowa
Department of Education's Compliance with the Unsafe Schools Choice
Option Provision* dated April 8, 2005. Per the request in your letter,
our response includes comments on the findings and recommendations.

Finding 1: LEAs did not report all USCO incidents resulting in 10-day
suspensions and expulsions.

**Response to Finding**: Based upon the comments provided in the Draft
Audit Report, the Iowa Department of Education does not dispute the
facts regarding the Des Moines or Davenport school districts. However,
the Department believes it is very important to discuss with staff from
both districts concerning how or why the districts under-reported the
number of incidents identified in the audit. The information gained from
these discussions will enable the Department to better respond to the
recommendations made by the auditors regarding Finding 1.

**Corrective Action in Response to Recommendation 1.1:** By June 30,
2006, the Iowa Department of Education will review and improve its
current procedures for onsite monitoring of the compliance of local
school districts with Iowa's USCO policy to include targeted follow-up
with districts identified through a desk audit process.

**Corrective Action in Response to Recommendation 1.2:** The Iowa
Department of Education will a) review its data dictionary for the
required data elements of the state's USCO policy in order to
standardize entry and increase the accuracy of data reported; b) discuss
with staff at the audited districts their internal procedures and
corrective action they may have taken; and c) train district personnel
on how to accurately submit data to meet the reporting requirements of
USCO. This process will be completed by Spring 2006.

**Corrective Action in Response to Recommendation 1.3:** While we agree
that information required for USCO should be accurately maintained by
school districts and accurately reported to the Iowa Department of
Education, we do not agree with the recommendation to request a
verification from districts that they reported all ten-day suspensions
and accurately reported punishments during the 2002-03 and 2003-04
school years.

As noted in the audit findings, "None of the schools reviewed would have
met Iowa's criteria for a Persistently Dangerous School (PDS)
designation." Complying with recommendation 1.3 will be a significant
time and effort burden on both the Department staff as well as the
districts. We do not have any evidence that asking districts to review
data/reports from the 2002-03 and 2003-04 school

years will result in any school being designated as PDS. Iowa school
districts have relatively low USCO incidents resulting in suspensions or
expulsions.

We believe that the effort devoted to meeting this recommendation is
better devoted to assuring that future reporting is conducted in an
accurate and timely manner. Our collective efforts in working with
districts to develop student information systems that will provide
accurate data to meet USCO requirements is a more productive investment
in time and effort.

Finding 2: LEAs did not offer the USCO transfer option.

**Response to Finding:** The Iowa Department of Education accepts the
results of the U.S. Department of Education's audit of a sample of
schools in a sample of school districts in Iowa and thus concurs with
Finding 2.

**Corrective Action in Response to Recommendation 2.1:** By Spring 2006,
the Iowa Department of Education will require that districts report the
number of transfer options offered, accepted, and completed. In
addition, the Department will incorporate into its review of local
school district records conducted during onsite visits to 20% of school
districts annually verification of a) the existence of LEA transfer
policies; b) confirmation that eligible students and their parents were
offered the transfer option; and c) the district's documentation of
parent notification of their option to transfer under either the whole
school option or the individual student choice option.

Corrective Action in Response to Recommendation 2.2: As stated in a
response to a previous draft of the USDE audit and consistent with prior
practice, the Iowa Department of Education has undertaken work with the
Iowa Association of School Boards (IASB) to provide school districts
with model/sample policies and policy guidance on how they can include a
transfer policy in their local policies. In addition, the Iowa
Department of Education will work with IASB to ensure that all LEAs are
well-informed of their obligations for parent notification and will
monitor the success of this effort. A sample policy will be published by
June 1, 2006.

**Corrective Action in Response to Recommendation 2.3**: The Iowa
Department of Education will undertake the procedures described in 2.1
above. In addition, the Department already has issued an informational
piece in its newsletter to local education agency superintendents.

Sincerely,

![](media/image5.png){width="1.875in" height="0.5833333333333334in"}

Judy Jeffrey, Director

[^1]: Iowa Chapter 11, Unsafe School Choice Option \[Subrule\]
    281---11.4. The individual student option permits victims of violent
    criminal offenses the opportunity to transfer to another school
    within the district.

[^2]: Violent criminal offenses are defined by Iowa code and included in
    the BACKGROUND section of this report.

[^3]: Number of unreported incidents does not include offenses that
    resulted in long-term suspensions or expulsions but were not
    reported to IDE.

[^4]: For all nine schools reviewed, we identified incidents that we
    considered violent criminal offenses that could have resulted in
    long-term suspensions or expulsions but were not reported as such.
    Examples of these incidents are provided in the OTHER MATTER section
    of this report.