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**JUN 25, 2004**

**Control Number ED-OIG/A05-D0038**

Mr. Thomas D. Watkins, Jr.

Superintendent of Public Instruction

Michigan Department of Education

P.O. Box 30008

Lansing, MI 48909

Dear Mr. Watkins:

This **Final Audit Report** presents the results of our audit of
Michigan's local educational agencies' (LEA) allocations of Elementary
and Secondary Education Act of 1965, as amended (ESEA), Title I, Part A
(Title I), funds to schools for the period July 1, 2001, through June
30, 2002 (2001-2002 school year). Our overall objective was to determine
whether selected LEAs in the State of Michigan complied with Title I of
the ESEA, as amended[^1], and regulations governing the allocation of
Title I funds to LEAs and schools. Specifically, we wanted to (1)
determine whether selected LEAs allocated Title I funds to the schools
with the highest percentages of poor children (that is, in rank order),

\(2\) determine whether only eligible schools were receiving Title I
funds, (3) determine whether the proper poverty measures were used and
that lower poverty schools were not receiving higher per-pupil
allocations than higher poverty schools, and (4) verify that the data
used to identify and count eligible poverty children was proper.

For the 2001-2002 school year, the Michigan Department of Education
(MDE) received \$349,305,562 in Title I funds (Basic and Concentration
grants) and allocated \$326,939,766 to 544 LEAs and \$13,995,123 to 157
Public School Academies (charter schools). Our audit of 15 LEAs'
allocation of \$120,447,182 of Title I funds to 366 public schools
disclosed that Michigan LEAs generally allocated Title I funds to the
schools with the highest percentages of poor children (that is, in rank
order) and generally used data to identify and count eligible poverty
children that was proper. However, our audit disclosed that 5 of the 15
LEAs did not always ensure that (1) Title I funds were only allocated to
eligible schools, (2) lower poverty schools were not receiving higher
per-pupil allocations than higher poverty schools and that proper
poverty measures were used, or (3) the data used to identify and count
eligible poverty children was accurate.

Specifically, we found that

1.  Warren Consolidated Schools (Warren) and Cheboygan Area Schools
    (Cheboygan) allocated \$246,117 of Title I funds to 3 ineligible
    schools.

2.  Warren, Dowagiac Union Schools (Dowagiac), and Cheboygan allocated
    higher per-pupil amounts to schools with lower concentrations of
    poverty than they allocated to schools with higher concentrations of
    poverty. As a result, 7 higher poverty schools received \$285,376
    less in Title I funds than they should have received.

3.  Detroit Public Schools (Detroit), Warren, and Oscoda Area Schools
    (Oscoda) used incorrect and/or inconsistent student count data. As a
    result, 4 schools were allocated \$20,755 less in Title I funds and
    10 schools were allocated \$1,030,813 more Title I funds than they
    should have received.

These instances of noncompliance occurred, in part, because MDE's
monitoring procedures were not adequate to ensure that the LEAs complied
with the requirements governing the allocation of Title I funds to
schools. Had the LEAs complied with the requirements, approximately
\$1.58 million of Title I funds might have been put to better use.

In addition, our audit disclosed a weakness in MDE's Title I allocation
calculation process. This weakness caused MDE to use incorrect free
lunch count data. The incorrect free lunch count data resulted in the
allocation of Title I funds to 59 charter schools to be understated by
\$48,835 for the 2001-2002 school year. MDE has acknowledged this
weakness and indicated that it has changed its programming code to
prevent this error in the future.

In its response to our draft audit report, MDE concurred with the
findings and generally agreed with the recommendations. However,
regarding Finding No. 1, MDE proposes to implement recommendation 1.3.
MDE suggests implementing recommendations 1.1 and 1.2 only if it finds
that the results of implementing recommendation 1.3, strengthening the
Michigan School Auditing Manual, and emphasizing the proper allocation
of Title I funds in the training it provides for the independent
auditors who perform the Single Audits are not adequate. (We have
included MDE's response in its entirety as an attachment.)

We disagree with MDE's alternative corrective action because this method
alone has been ineffective in the past. We continue to recommend that
the Assistant Secretary for Elementary and Secondary Education direct
MDE to require LEAs to submit their Title I allocation calculations as
part of their annual consolidated applications and review the LEAs'
allocations as part of the application approval process.

# AUDIT RESULTS

Finding No. 1 Monitoring of LEAs' Allocations of Title I Funds to
Schools Needs Improvement

Five of the 15 LEAs we audited did not allocate Title I funds entirely
in accordance with the applicable law and regulations. Two LEAs
allocated Title I funds to ineligible schools, 3 LEAs allocated higher
Title I per-pupil amounts to lower poverty schools than to higher
poverty schools, and 3 LEAs used incorrect and/or inconsistent student
count data to compute schools' poverty percentages and allocate Title I
funds to schools. The incorrect allocations resulted in approximately
\$1.58 million in Title I funds not being delivered to the appropriate
location (that is, to the neediest areas). We concluded that MDE's
monitoring procedures were not adequate to provide reasonable assurance
that LEAs' allocations of Title I funds to schools complied with the
applicable law and regulations.

Title I Funds Allocated to Ineligible Schools

For the 2001-2002 school year, 2 of the 15 LEAs allocated Title I funds
to 3 ineligible schools. The 3 schools did not qualify as Title I
eligible schools because their poverty percentages were below the
eligibility requirements set forth in the regulations and the law.

Pursuant to 34 C.F.R. § 200.28 (a)(1),[^2] an LEA shall allocate funds
under Subpart A to school attendance areas or schools in rank order on
the basis of the total number of children from low-income families in
each area or school. Pursuant to the ESEA, Title I, Section 1113(a), an
LEA shall use funds received under this part only in eligible school
attendance areas. The term eligible school attendance area means a
school attendance area in which the percentage of children from
low-income families is at least as high as the percentage of children
from low-income families served by the LEA as a whole. According to
Section 1113(b), an LEA may designate as eligible any school attendance
area or school in which at least 35 percent of the children are from
low-income families; an LEA also may use funds received under this part
in a school that is not in an eligible school attendance area, if the
percentage of children from low-income families enrolled in the school
is equal to or greater than the percentage of such children in a
participating school attendance area of such agency.

-   Warren allocated \$103,226 in Title I funds to one ineligible
    school. The school was ineligible because Warren used an enrollment
    count of 370 in computing the school's poverty percentage instead of
    the correct enrollment count of 390. Using the correct enrollment
    count, the school's poverty percentage (20.8 percent) was below the
    poverty percentage (21.3 percent) of an eligible school that elected
    not to receive Title I funding. MDE advised Warren that it was
    allowable not to allocate Title I funds to this eligible school
    provided no schools with lesser poverty percentages were allocated
    Title I funds.

-   Cheboygan allocated \$142,891 in Title I funds to two ineligible
    schools. The two schools were ineligible because their poverty
    percentages of 29 percent and 26 percent, were below the average of
    the elementary grade span grouping poverty percentage of 39 percent,
    below the LEA wide poverty percentage of 37 percent, and below the
    35 percent threshold set forth in the law.

The \$246,117 these two LEAs allocated to ineligible schools should have
been allocated to Title I eligible schools and on behalf of eligible
students attending non-public schools.

Higher Per-Pupil Amounts Allocated to Lower Poverty Schools

For the 2001-2002 school year, 3 of the 15 LEAs allocated higher Title I
per-pupil amounts to lower poverty schools. Pursuant to 34 C.F.R. §
200.28 (c) and (d), an LEA is not required to allocate the same
per-pupil amount to each participating school attendance area or school
provided the LEA allocates higher per-pupil amounts to areas or schools
with higher concentrations of poverty than to areas or schools with
lower concentrations of poverty. An LEA may reduce the amount of funds
allocated under this section to a school attendance area or school if
the area or school is spending supplemental State or local funds for
programs that meet the requirements in 34 C.F.R. § 200.62 (c).

As a result of the three LEAs allocating higher Title I per-pupil
amounts to lower poverty schools, seven higher poverty schools received
\$285,376 less in Title I funds than they would have received if all
eligible schools were allocated the same per-pupil amount.

-   Warren used budgeted personnel and supply costs to arrive at the
    final amount of Title I funds it allocated to seven of its eight
    eligible schools. As a result, three higher poverty schools were
    allocated \$99,582 less in Title I funds than they would have
    received and one higher poverty school was allocated \$15,565 more
    in Title I funds than it would have received had all schools been
    allocated the same per-pupil amount of \$727.28.

-   Dowagiac allocated Title I funds to its five Title I eligible
    elementary schools based on personnel and supply costs rather than
    the per-pupil amount and the schools' free and reduced lunch counts.
    As a result, two schools with higher concentrations of poverty were
    allocated \$52,115 less in Title I funds and three schools with
    lower concentrations of poverty were allocated \$52,113 more in
    Title I funds than they would have received had all five elementary
    schools been allocated the same per-pupil amount of \$664.78.

-   Cheboygan allocated Title I funds based on the budgeted expenses for
    Title I teachers and instructional aides at each school building
    rather than the per-pupil amount and the schools\' free and reduced
    lunch counts. As a result, two higher poverty schools were allocated
    \$133,679 less in Title I funds than they would have received had
    the three eligible schools been allocated the same per-pupil amount
    of \$802.32.

## Incorrect and/or Inconsistent Student Count Data Used to Allocate Title I Funds

For the 2001-2002 school year, 3 of 15 LEAs used incorrect and/or
inconsistent student count data to compute schools' poverty percentages
and to allocate Title I funds to schools. Pursuant to the ESEA, Title I,
Section 1113(c)(1), an LEA must allocate funds received under this part
to eligible school attendance areas or eligible schools, identified
under subsections (a) and (b), in rank order, on the basis of the total
number of children from low-income families in each area or school.

-   Detroit incorrectly transferred free lunch counts from the data
    source to its allocation spreadsheet when calculating schools\'
    poverty percentages and allocating Title I funds to 4 of its 249
    schools. The use of incorrect free lunch counts resulted in the over
    allocation of Title I funds to two schools totaling \$172,049 and
    the under allocation of Title I funds to two schools totaling
    \$16,584.

-   Detroit did not use the same student counts to compute each school's
    poverty percentage that it used to allocate Title I funds to
    schools. Detroit used membership counts from the fall 2000 head
    count and free and reduced lunch counts from February 12, 2001, to
    calculate the poverty percentages it used to identify and rank
    eligible schools. Detroit then used the free and reduced lunch
    counts from February 12, 2001, to allocate Title I funds to schools.
    Using consistent count data, our recalculation of the Title I
    allocation for 17 of Detroit's 249 schools showed that 7 Detroit
    schools were over allocated \$854,593 of Title I funds. In addition,
    Detroit used membership counts in calculating the poverty
    percentages for 6 schools that were larger than the counts shown on
    the fall 2000 head count report. The use of larger membership counts
    caused the poverty percentages for six schools to be understated,
    but it did not affect the amount of Title I funds allocated to the
    schools. A Detroit Title I official concurred that Detroit's use of
    counts from 2 different time periods results in incongruent data
    that affects the allocation of Title I funds to schools. The Title I
    official indicated that Detroit will change its process. In the
    future, Detroit plans to use the fall count dates for both the
    enrollment and free and reduced lunch counts and use electronic
    merging of count data to eliminate human error in the allocation
    calculation process.

-   Warren used incorrect enrollment counts in its allocation of Title I
    funds for the 2001-2002 school year for two schools. Warren's use of
    enrollment counts for two schools that were less than counts shown
    in the data source caused the schools' poverty percentages to be
    overstated and affected the Title I eligibility of one school.[^3] A
    Warren Title I official indicated that the use of incorrect
    enrollment counts occurred because of human error in entering count
    data into its Title I allocation spreadsheet. Warren indicated that
    it has begun receiving and loading count data electronically to
    reduce human error and increase efficiency in its Title I allocation
    process.

-   Oscoda used free and reduced lunch counts in calculating the
    schools\' poverty percentages and allocating Title I funds to
    schools that were different than the counts shown on the source
    document (dated February 14, 2001). For four schools, the free and
    reduced lunch counts Oscoda used were smaller and for one school the
    count used was larger than the counts shown on the source document.
    The enrollment counts Oscoda used were smaller than the enrollment
    counts shown on the source document for all five schools. The use of
    free and reduced lunch counts that were different resulted in the
    under allocation of \$4,171 of Title I funds to two schools and the
    over allocation of \$4,171 of Title I funds to one school.

As a result of the 3 LEAs using incorrect and/or inconsistent student
count data to compute schools' poverty percentages and to allocate Title
I funds to schools, 4 schools were allocated \$20,755 less in Title I
funds and 10 schools allocated \$1,030,813 more in Title I funds than
they would have received had correct and consistent student count data
been used.

Monitoring LEAs' Allocations of Title I Funds to Schools

The above instances of noncompliance indicate that MDE's monitoring
procedures were not adequate to ensure that LEAs complied with the
requirements governing the allocation of Title I funds to schools. MDE
does not require its LEAs to include, as part of the consolidated
application, their allocations made to schools. Instead, MDE relies on
the LEAs' Single Audits to ensure that Title I funds are allocated to
schools in accordance with the law and regulations. MDE provides the
Michigan School Auditing Manual to assist independent auditors in
meeting the federal Office of Management and Budget Circular A-133 audit
requirements. The instances of noncompliance identified in our report
should have been disclosed as violations of the Title I requirements in
the Single Audit reports. However, our review of the Single Audit work
papers for the LEAs disclosed that the auditors did not identify these
violations of the Title I requirements. In addition, we could not rely
on the work of the auditors because there was insufficient evidence that
ample testing was completed in the area of eligibility (enrollment
counts and free and reduced lunch counts). MDE's reliance on the LEAs'
Single Audits to ensure that LEAs properly allocate Title I funds to
schools is not sufficient to provide reasonable assurance that funds
were allocated appropriately.

#### Recommendations

We recommend that the Assistant Secretary for Elementary and Secondary
Education direct MDE to

1.  require LEAs to submit their Title I allocation calculations as part
    of their annual consolidation applications,

2.  review the LEAs' allocations as part of approving their
    applications, and

3.  provide technical assistance to the Cheboygan, Detroit, Dowagiac,
    Oscoda, and Warren LEAs to ensure their responsible officials
    understand the Title I allocation requirements.

Finding No. 2 System Weakness Affected the Allocation of Title I Funds
to Charter Schools

The free lunch count that MDE used to calculate the allocation of Title
I funds to charter schools for the 2001-2002 school year was overstated.
MDE used a free lunch count for Detroit of 102,584 rather than the
correct adjusted free lunch count of 100,403.

Pursuant to 34 C.F.R. § 200.20 and ED Office of Elementary and Secondary
Education guidance dated June 1998 titled "Basic Programs In Local
Educational Agencies," MDE is responsible for adjusting the LEAs' Title
I allocations received from ED to account for LEA changes and the
creation of special LEAs, such as charter schools, that are eligible for
Title I funds but not reflected in ED's allocations.

The overstated free lunch count caused the equating ratio that MDE used
in calculating the allocation of Title I funds to charter schools to be
understated by 0.39367 percent. The understated equating ratio resulted
in the allocation of Title I funds to 59 charter schools being \$48,835
less than it would have been had the correct free lunch count been used.
The use of the incorrect free lunch count was caused by a system
weakness that did not allow corrections to the free lunch count after
the running of the initial program application. MDE acknowledged this
system weakness and informed us that it recently changed the programming
code to prevent this error in the future.

### 

### Recommendation

We recommend that the Assistant Secretary for Elementary and Secondary
Education

1.  verify that MDE's change to the program code is ensuring that
    correct free lunch counts are captured and used to calculate the
    Title I allocations for charter schools.

# BACKGROUND

The Title I program is authorized under the ESEA, as amended by the
Improving America's Schools Act of 1994, Public Law 103-382. Title I
grants are intended to help elementary and secondary schools establish
and maintain programs that will improve the educational opportunities of
low-income and disadvantaged children. The funds are intended to provide
instruction and instructional support for these disadvantaged children
so they can master challenging curricula and meet state standards in
core academic subjects.

Title I funds are distributed from ED to states based on data that are
measured at the LEA and state levels. The state's allocation is the sum
of the LEAs' allocations as determined by ED. However, ED's allocations
are not the final amounts the LEAs receive because the state must adjust
the allocations to

-   reserve funds for state administration (up to 1 percent) and for
    school improvement activities (no more than 0.5 percent but at least
    \$200,000); and

-   account for changes in district boundaries, consolidations, and
    creation of special districts such as charter schools or regional
    vocational/technical schools that are eligible for Title I funds but
    not reflected in ED's allocations.

In distributing funds to schools, LEAs are subject to several key
restrictions. An LEA must determine which school attendance areas
(schools) are eligible to participate in Title I. A school attendance
area is generally eligible to participate if the percentage of children
from low-income families is at least as high as the percentage of
children from low-income families in the LEA as a whole or at least 35
percent poverty. An LEA also may designate and serve a school in an
ineligible attendance area if the percentage of children from low-income
families enrolled in that school is equal to or greater than the
percentage of such children in a participating school area. When
determining eligibility, an LEA must select a poverty measure from among
those specified in the statutes. The LEA must use the measure
consistently across the LEA to rank all school attendance areas
according to their percentage of poverty.

LEAs allocate funds to eligible schools or attendance areas in rank
order according to their poverty percentages. An LEA must serve those
schools or areas above 75 percent poverty, including any middle or high
schools, before it serves any schools or areas with a poverty percentage
below 75 percent. Once all schools and areas above 75 percent poverty
are served, the LEA may serve lower-poverty areas and schools either by
continuing with the LEA-wide ranking or by ranking its schools below 75
percent poverty according to grade-span groupings. An LEA with an
enrollment of less than 1,000 students or with only one school per grade
span is not required to rank its school attendance areas.

LEAs are not required to allocate the same per-pupil amount to each
school. If they choose not to allocate the same per-pupil amount to each
school, they must allocate higher per-pupil amounts to poorer schools
than they allocate to schools with lower concentrations of poverty. LEAs
also may apply for and receive waivers of any of these allocation
requirements.

**OBJECTIVE, SCOPE, AND METHODOLOGY**

The overall objective of our audit was to determine whether selected
LEAs in the State of Michigan complied with Title I of the ESEA, as
amended, and regulations governing the allocation of Title I funds to
LEAs and schools. Specifically, we wanted to (1) determine whether
selected LEAs allocated Title I funds to the schools with the highest
percentages of poor children (that is, in rank order), (2) determine
that only eligible schools were receiving Title I funds, (3) determine
that the proper poverty measures were used and that lower poverty
schools were not receiving higher per-pupil allocations than higher
poverty schools, and (4) verify that the data used to identify and count
eligible poverty children was proper. Our audit covered the period July
1, 2001, through June 30, 2002.

To achieve our audit objectives, we

1.  reviewed MDE's management control structure, policies, procedures,
    and practices applicable to its allocation of Title I funds to LEAs
    and monitoring of LEAs' allocations of Title I funds to schools;[^4]

2.  obtained the universe of LEAs from MDE;

3.  stratified the universe of 544 LEAs[^5] based on the amount of Title
    I funds received into 7 strata, selected the only 2 LEAs (Detroit
    and Flint Community Schools) that made up the first 2 strata, and
    randomly selected 13 additional LEAs from the next 4 largest strata;

4.  obtained information regarding the 15 LEAs' allocation processes and
    allocations for the 2001-2002 school year;

5.  audited each LEA's allocation process and allocation by

\(a\) identifying the key people involved in the allocation process,

> \(b\) obtaining and reviewing copies of the two most recent Single
> Audit reports and management letters,
>
> \(c\) obtaining a list of the Title I allocations to schools,
>
> \(d\) gaining an understanding of the allocation process and related
> controls,
>
> \(e\) determining whether Title I funds were allocated to schools with
> the highest percentage of poor children (rank order) and only to
> eligible schools,
>
> \(f\) ensuring lower poverty schools were not receiving higher per
> pupil allocations than higher poverty schools and that the poverty
> measure used was proper,
>
> \(g\) verifying that the student count data used in the allocation was
> accurate and inclusive in accordance with the ESEA and the applicable
> regulations, and

(h) assessing the reliability of computer-processed data applicable to
    the allocation of Title I funds to schools.

We also relied, in part, on computer-processed data that MDE used to
allocate Title I funds to LEAs. The data we used were the LEA grant
allocation amounts, the student enrollment counts, and counts of
students eligible for free and reduced priced lunches contained in MDE's
computerized student database, Michigan Education Information System. To
determine whether this data was reliable, we first assessed the adequacy
of the related computer system controls. We then compared the student
enrollment count data to the LEAs' Intermediate School Districts' pupil
membership count report. We also compared the student counts for free
and reduced lunches contained in MDE's school meals database to the
LEAs' food service count data for selected LEAs. Based on our assessment
and tests, we concluded that the computer-processed data MDE provided
was sufficiently reliable for the purposes of our audit.

We conducted our audit work from June 16, 2003, through February 9,
2004. As part of our audit, we visited (1) MDE's offices in Lansing,
Michigan; (2) Flint Community Schools' offices in Flint, Michigan; and
(3) Detroit Public Schools' offices in Detroit, Michigan. We did not
visit the other 13 LEAs' offices. Instead, we obtained the necessary
information from those 13 LEAs and conducted our audit work in Chicago,
Illinois, and St. Paul, Minnesota. We held an exit conference with MDE
officials on March 4, 2004.

Our audit was performed in accordance with generally accepted government
auditing standards appropriate to the scope of the audit described
above.

**STATEMENT ON MANAGEMENT CONTROLS**

As part of our audit, we assessed the adequacy of MDE's management
control structure, policies, procedures, and practices applicable to its
allocation of Title I funds to LEAs. To make our assessment, we
classified MDE's controls into the following categories:

-   Allocation of Title I funds to LEAs, including controls over the
    completeness and accuracy of student enrollment and free and reduced
    lunch counts;

-   Monitoring LEAs' allocations of Title I funds to schools

Because of inherent limitations, a study and evaluation made for the
limited purpose described above would not necessarily disclose all
material weaknesses in MDE's Title I management controls. Our assessment
disclosed two management control weaknesses related to MDE's
administration of the Title I program. These weaknesses include (1)
monitoring procedures that are not sufficient to ensure that LEAs'
allocations of Title I funds to schools comply with the law and
regulations and (2) controls over count data that are inadequate to
ensure that MDE used accurate counts in calculating the allocation of
Title I funds to LEAs and charter schools. These weaknesses and their
effects are discussed in the **AUDIT RESULTS** section of this report
(Finding No. 1 and Finding No. 2, respectively).

We did not assess the adequacy of the management control structure of
the 15 LEAs that we audited because such assessments were not necessary
to achieve our audit's objective. Instead, we obtained an understanding
of the processes the 15 LEAs used to allocate Title I funds to schools
and determined whether the processes were in compliance with the
applicable law and regulations. Our review disclosed 8 instances of
non-compliance with federal law and regulations that were caused by
management control weaknesses at 6 LEAs. Two LEAs allocated Title I
funds to ineligible schools, 3 LEAs allocated higher Title I per-pupil
amounts to lower poverty schools than to higher poverty schools, and 3
LEAs used incorrect and/or inconsistent student count data to compute
schools' poverty percentages and allocate Title I funds to schools.
These weaknesses and their effects are discussed in the **AUDIT
RESULTS** section of this report (Finding No. 1).

# 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. Determination of corrective action
to be taken will be made by the appropriate ED officials.

If you have 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 ED official, who will consider them before taking final
action on the audit.

Raymond J Simon, Assistant Secretary

> Office of Elementary and Secondary Education Secretary

U. S. Department of Education

FOB-6, Room 3W315

400 Maryland Avenue, SW

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 findings and
recommendations contained therein. Therefore, receipt of your comments
within 30 days would be appreciated.

In accordance with the 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.

> Sincerely,

/s/

> Richard J. Dowd

Regional Inspector General

for Audit

Attachment

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[^1]: The ESEA was reauthorized by the No Child Left Behind Act of 2001
    on January 8, 2002.

[^2]: Unless otherwise noted, all regulatory citations are to the
    version dated July 1, 2000.

[^3]: See ***Title I Funds Allocated to Ineligible Schools*** section of
    this report.

[^4]: Our review of MDE's management controls included (1) a review of
    the MDE single audit report for the two years ended September 30,
    2001, (2) the performance audit report issued on MDE's Office of
    Field Services for the period October 1998 through July 2001, (3)
    discussions with Michigan Office of the Auditor General staff, and
    (4) a review of the Michigan Office of the Auditor General's audit
    working papers related to MDE and Title I allocations to LEAs. In
    addition, we interviewed MDE's internal auditor and reviewed
    selected documents and reports related to selected LEAs.

[^5]: We excluded 157 charter schools from the universe.