District of Columbia Department of Education (DC SEA)

**February 27 -- March 10, 2006**

**Scope of Review:** A team from the U.S. Department of Education's (ED)
Student Achievement and School Accountability Programs (SASA) office
monitored the District of Columbia Department of Education (DC SEA)
February 27--March 10, 2006. This was a comprehensive review of DC SEA's
administration of the following programs authorized by the Elementary
and Secondary Education Act of 1965 (ESEA), as amended by the No Child
Left Behind Act (NCLB): Title I, Part A; Title I, Part B, Subpart 3; and
Title I, Part D. Also reviewed was Title X, Part C, Subtitle B, of NCLB
(also known as the McKinney-Vento Homeless Education Assistance
Improvements Act of 2001).

Two representative(s) of ED's Office of the Chief Financial Officer's
(OCFO) Internal

Control Evaluation Group participated with SASA staff in the review of
selected

fiduciary elements of the onsite Title I monitoring review. The Improper
Payments

Information Act of 2002 requires ED to conduct a risk assessment of the
Title I program

to determine if program funds are being delivered and administered in a
manner that

complies with the congressional appropriation. The OCFO
representative(s) is/are

working with SASA staff in a cooperative effort on selected Title I
monitoring reviews to

carry out the required assessment. Findings related to this portion of
the review are

presented under the Title I, Part A Fiduciary Indicators.

In conducting this comprehensive review, the ED team carried out a
number of major activities. In reviewing the Part A program, the ED team
conducted an analysis of State assessments and State Accountability
System Plans, reviewed the effectiveness of the instructional
improvement and instructional support measures established by the State
to benefit local educational agencies (LEAs) and schools, and reviewed
compliance with fiscal and administrative oversight requirements
required of the state educational agency (SEA). During the onsite week,
the ED team visited the District of Columbia Public Schools (DCPS) LEA
and interviewed administrative staff, visited with representatives from
five schools in DCPS that have been identified for improvement, and
conducted one parent meeting. The team also visited two charter school
LEAs, and interviewed teachers and administrative staff. The ED team
then interviewed DC SEA personnel to confirm data collected in each of
the three monitoring indicator areas.

In its review of the Title I, Part B, Subpart 3 Even Start program, the
ED team examined the State's request for proposals, State Even Start
guidance, State indicators of program quality, and the most recent
applications and local evaluations for the Family Place, Inc., and the
Even Start Multicultural Family Literacy Program local projects located
in the DC SEA**.** During the onsite review, the ED team visited these
local projects and interviewed administrative and instructional staff.
The ED team also interviewed the Even Start State Coordinator to confirm
information obtained at the local sites and to discuss State
administration issues.

In its review of the Title I, Part D program, the ED team examined DCPS
application for funding, procedures and guidance to State agency (SA)
programs and DCPS oversight and monitoring plan and activities. ED
reviewed Title I Part D programs at the Oak Hill Academy. The ED team
interviewed administrative, program and teaching staff. The ED team also
interviewed the DC SEA Title I, Part D State coordinator to confirm
information obtained at the local site and discuss administration of the
program.

**Previous Audit Findings:** The DC SEA has had numerous findings in
successive State single audits for many years, many of which are
recurring findings. ED continues to work with the DC SEA to address
these issues through systemic correction action.

**Previous Monitoring Findings**: ED last reviewed Title I programs in
the DC SEA in May 2003. ED identified compliance findings in the areas
of private schools (funding, equitable participation, eligibility, and
consultation)**,** reallocation policies, requirements concerning
property, equipment, and supplies purchased with Title I funds, and
State committee of practitioners as a result of that review.

**[Overarching Requirement -- SEA Monitoring]{.underline}**

A State's ability to fully and effectively implement the requirements of
NCLB is directly related to the extent to which it is able to regularly
monitor it's LEAs and provide quality technical assistance based on
identified needs. This principle applies across all Federal programs
under NCLB.

Federal law does not specify the particular method or frequency with
which States must monitor their grantees, and States have a great deal
of flexibility in designing their monitoring systems. Whatever process
is used, it is expected that States have mechanisms in place sufficient
to ensure that States are able to collect and review critical
implementation data with the frequency and intensity required to ensure
effective (and fully compliant) programs under NCLB. Such a process
should promote quality instruction and lead to achievement of the
proficient or advanced level on State standards by all students.

[Finding]{.underline}: The DC SEA did not ensure that charter school
LEAs develop and implement corrective actions for issues of
noncompliance identified through its monitoring process. The ED team
reviewed the most recent monitoring reports for the two charter schools
visited during the onsite week -- Sasha Bruce Public Charter School
(SBPCS), and Booker T. Washington Public Charter School (BTWPCS). The DC
SEA monitored the BTWPCS in June of 2003 and issued a report in July of
2003, which included findings in the areas of fiscal controls and
teacher quality requirements under NCLB. Although the DC SEA's process
requires LEAs to respond with corrective action plans within 30 days, at
the time of the review, the charter school LEA had not submitted any
corrective action plans. The DC SEA staff indicated that the BTWPCS had
'not responded yet.'

[Citation]{.underline}: Section 80.40 of the Education Department
General Administrative Regulations (EDGAR) -- Grantees must monitor
grant and subgrant activities to ensure compliance with applicable
Federal requirements.

Section 9304 (a) of the ESEA requires that the SEA must ensure that (1)
programs authorized under ESEA are administered in accordance with all
applicable statutes, regulations, program plans, and applications; and
(2) the State will use fiscal control and funds accounting procedures
that will ensure the proper disbursement of and accounting for Federal
funds.

[Further action required]{.underline}: The DC SEA must ensure that it
has an effective method to monitor for compliance with all requirements
of Title I, Part A, Part B, and Part D of the ESEA, including procedures
to identify and correct issues of noncompliance. The DC SEA must provide
documentation that its monitoring procedures ensure timely
identification and correction of all identified issues of noncompliance.

Title I, Part A Monitoring

**Summary of Monitoring Indicators**

+---------+---------------------------------------+--------------+-----+
| **\     |                                       |              |     |
| Mon     |                                       |              |     |
| itoring |                                       |              |     |
| Area 1, |                                       |              |     |
| Title   |                                       |              |     |
| I, Part |                                       |              |     |
| A:      |                                       |              |     |
| Ac      |                                       |              |     |
| countab |                                       |              |     |
| ility** |                                       |              |     |
+---------+---------------------------------------+--------------+-----+
| **In    | **Description**                       | **Status**   | # P |
| dicator |                                       |              | age |
| N       |                                       |              |     |
| umber** |                                       |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.1     | The SEA has approved academic content | Finding      | 5   |
|         | standards for all required subjects   |              |     |
|         | or an approved timeline for           |              |     |
|         | developing them.                      |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.2     | The SEA has approved academic         | Finding      | 5   |
|         | achievement standards and alternate   |              |     |
|         | academic achievement standards in     |              |     |
|         | required subject areas and grades or  |              |     |
|         | an approved timeline to create them.  |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.3     | The SEA has approved assessments and  | Finding      | 5   |
|         | alternate assessments in required     |              |     |
|         | subject areas and grades or an        |              |     |
|         | approved timeline to create them.     |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.4     | Assessments should be used for        | Met          | NA  |
|         | purposes for which such assessments   | requirements |     |
|         | are valid and reliable, and be        |              |     |
|         | consistent with relevant, nationally  |              |     |
|         | recognized professional and technical |              |     |
|         | standards.                            |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.5     | The SEA has implemented all required  | Met          | NA  |
|         | components as identified in its       | requirements |     |
|         | accountability workbook.              |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.6     | The SEA has published an annual       | Finding      | 6   |
|         | report card as required and an Annual |              |     |
|         | Report to the Secretary.              |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.7     | The SEA has ensured that LEAs have    | Finding      | 6   |
|         | published annual report cards as      |              |     |
|         | required.                             |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.8     | The SEA indicates how funds received  | Met          | NA  |
|         | under Grants for State Assessments    | requirements |     |
|         | and related activities (Section 6111) |              |     |
|         | will be or have been used to meet the |              |     |
|         | 2005-06 and 2007-08 assessment        |              |     |
|         | requirements of NCLB.                 |              |     |
+---------+---------------------------------------+--------------+-----+
| 1.9     | The SEA ensures that LEAs meet all    | Met          | NA  |
|         | requirements for identifying and      | requirements |     |
|         | assessing the academic achievement of |              |     |
|         | limited English proficient students.  |              |     |
+---------+---------------------------------------+--------------+-----+

**Title I, Part A - Accountability**

**Indicator 1.1 - The SEA has approved academic content standards for
all required subjects or an approved timeline for developing them.**

**[Finding]{.underline}:** The DC SEA does not yet have approved science
content standards or performance level descriptors, as required.

[Citation]{.underline}: Section 200.1 of the Title I regulations
requires adoption of challenging science content standards as well as
achievement levels and descriptors by 2005-2006.

[Further action required]{.underline}: The DC SEA must complete all
activities needed to produce final science content standards, and secure
Board adoption. The DC SEA must submit evidence of adoption and
preparation of draft performance level descriptors in science for ED
approval as part of the peer review of State assessment systems under
NCLB.

**Indicator 1.2 - The SEA has approved academic achievement standards
and alternate academic achievement standards in required subject areas
and grades or an approved timeline to create them.**

**[Finding]{.underline}:** The DC SEA does not yet have approved
achievement standards in reading/language arts and mathematics as
required, but has a plan and timeline (DC-CAS Program Design Plan) for
completing the creation and approval of achievement standards by fall
2006.

[Citation]{.underline}: The Title I regulations at section 200.6
requires that each SEA's statewide assessment system must be aligned
with the State's academic content and achievement standards and provide
coherent information about student attainment of such standards. The
system must also provide one or more alternate assessments for students
with disabilities who cannot participate in the regular assessment.

[Further action required]{.underline}: The DC SEA must complete all
activities needed to establish academic achievement standards in
reading/language arts and mathematics at all grades tested and may
establish alternate achievement standards using a documented and
validated standard setting process. The DC School Board must approve all
achievement standards. In addition, the DC SEA must provide evidence
that all requirements have been met as part of the peer review of State
assessment systems under NCLB.

**Indicator 1.3 - The SEA has approved assessments and alternate
assessments in required subject areas and grades or an approved timeline
to create them.**

**[Finding]{.underline}:** Because it chose not to complete the
requirements of the compliance agreement regarding its assessment system
under the Improving America's Schools Act, the DC SEA is currently out
of compliance in this area. The DC SEA has done substantial appropriate
work in preparation for the initial assessment system and is expected to
administer standards-based assessments in reading/language arts and
mathematics at grades 3-8 and 10 in spring 2006.

[Citation]{.underline}: Section 1111(b)(3) of the ESEA requires full
implementation in 2005-2006 of a system of yearly academic assessments
in reading/language arts and mathematics administered in grades 3-8 and
once in high school.

[Further action required]{.underline}: The DC SEA must submit evidence
that it has completed the tasks required to implement the comprehensive
assessment system in language arts and mathematics in spring 2006 as
listed in the DC-CAS Program Design Plan, establish achievement
standards during the summer and use those as the basis for adequate
yearly progress (AYP) determinations for all schools and LEAs.

Indicator 1.6 - The SEA has published an annual Report Card as required
and an Annual Report to the Secretary.

**[Finding]{.underline}:** The DC SEA does not publish a State report
card that includes all required components.

[Citation]{.underline}: Section 1111(h)(1)(C) of the ESEA lists the
information required in the annual State report card.

[Further action required]{.underline}: In addition to the data currently
provided in the State report card, the DC SEA must include the
following: aggregate achievement at each proficiency level disaggregated
by the required subgroups; comparison of results with the State's annual
measurable objectives; the most recent two-year trend in each subject
area (as soon as available); aggregate information on graduation rate
and the other indicator used for elementary and middle schools;
information on each LEA regarding making AYP, including the number and
name of each school identified for improvement; the qualifications of
teachers; the percentage of teachers teaching with provisional
credentials; and the percent of classes not taught by highly qualified
teachers in the aggregate and disaggregated by high poverty compared to
low poverty schools. The DC SEA must submit a corrected copy of the
report card once it is completed.

**Indicator 1.7 - The SEA has ensured that LEAs have published annual
report cards as required.**

**[Finding]{.underline}:** The DC SEA is currently comprised of 53 LEAs.
None of the LEA report Cards include all required components.

[Citation]{.underline}: Section 1111(h)(2)(B) of the ESEA lists the
information required in the annual LEA report card.

[Further action required]{.underline}: The DC SEA may either prepare LEA
report cards allowing for review and correction when necessary, or may
implement procedures to review locally developed report cards that
include all required components. In addition to the data currently
provided in the LEA report card, include the following: all information
required for the State report card as applied to the LEA and all schools
within the LEA plus the number and percent of schools within the LEA
identified for improvement and how long so identified; how achievement
results for students within the LEA compared to achievement in the State
as a whole; for individual schools, show how the achievement of its
students on the statewide assessment and other AYP indicators compared
to students in the LEA and State as a whole. The DC SEA must submit a
copy of the corrected report card once it is completed.

+--------+---------------------------------------+------------+-------+
| ## Mon |                                       |            |       |
| itorin |                                       |            |       |
| g Area |                                       |            |       |
|  2, Ti |                                       |            |       |
| tle I, |                                       |            |       |
|  Part  |                                       |            |       |
| A: Ins |                                       |            |       |
| tructi |                                       |            |       |
| onal S |                                       |            |       |
| upport |                                       |            |       |
+--------+---------------------------------------+------------+-------+
| *      | ## Description                        | ## Status  | ##    |
| *Indic |                                       |            |  Page |
| ator** | ##                                    |            |       |
|        |                                       |            |       |
| **Nu   |                                       |            |       |
| mber** |                                       |            |       |
+--------+---------------------------------------+------------+-------+
| 2.1    | The SEA designs and implements        | Finding    | 9     |
|        | procedures that ensure the hiring and |            |       |
|        | retention of qualified                |            |       |
|        | paraprofessionals and ensure that     |            |       |
|        | parents are informed of educator      |            |       |
|        | credentials as required.              |            |       |
+--------+---------------------------------------+------------+-------+
| 2.2    | The SEA has established a statewide   | Finding    | 9     |
|        | system of support that provides, or   |            |       |
|        | provides for, technical assistance to |            |       |
|        | LEAs and schools as required.         |            |       |
+--------+---------------------------------------+------------+-------+
| 2.3    | The SEA ensures that the LEA and      | Finding    | 10    |
|        | schools meet parental involvement     |            |       |
|        | requirements.                         |            |       |
+--------+---------------------------------------+------------+-------+
| 2.4    | The SEA ensures that schools and LEAs | Met        | NA    |
|        | identified for improvement,           | r          |       |
|        | corrective action, or restructuring   | equirement |       |
|        | have met the requirements of being so |            |       |
|        | identified.                           |            |       |
+--------+---------------------------------------+------------+-------+
| 2.5    | The SEA ensures that requirements for | Reco       | 12    |
|        | public school choice are met.         | mmendation |       |
+--------+---------------------------------------+------------+-------+
| 2.6    | The SEA ensures that requirements for | Reco       | 12    |
|        | the provision of supplemental         | mmendation |       |
|        | educational services (SES) are met.   |            |       |
+--------+---------------------------------------+------------+-------+
| 2.7    | The SEA ensures that LEAs and schools | Finding    | 12    |
|        | develop schoolwide programs that use  |            |       |
|        | the flexibility provided to them by   |            |       |
|        | law to improve the academic           |            |       |
|        | achievement of all students in the    |            |       |
|        | school.                               |            |       |
+--------+---------------------------------------+------------+-------+
| 2.8    | The SEA ensures that LEA targeted     | Met        | NA    |
|        | assistance programs meet all          | r          |       |
|        | requirements.                         | equirement |       |
+--------+---------------------------------------+------------+-------+

Indicator 2.1 - The SEA designs and implements procedures that ensure
the hiring and retention of qualified paraprofessionals and ensure that
parents are informed of educator credentials as required.

[Finding (1)]{.underline}: The DC SEA does not have a system in place to
ensure that all instructional paraprofessionals hired in its LEAs before
January 8, 2002, and working in a program supported with Title I funds,
will be qualified by the end of the 2004-2006 school year, as required.

DCPS obtains information about the status of paraprofessionals and their
progress toward meeting the requirements through a school-by-school
self-reporting process. As of March 23, 2006, only 3 schools had
reported their data. A list of paraprofessionals generated in November
2004 revealed that 1,706 were employed by DCPS. Of that number, 3
paraprofessionals indicated that they had not completed high school; 384
said they completed high school or obtained a GED; and 187 had completed
1 to 4 years of college. Based on available statistics, 170 individuals
provided no information consistent with above-referenced categories. The
DC SEA informed the ED team that it had not verified the college
transcripts of the paraprofessionals who responded to the survey. In the
absence of a tracking system, the DC SEA is unable to monitor the
progress of paraprofessionals toward meeting the highly qualified
requirements within the required time frame.

[Citation]{.underline}: Section 1119(c)(1) of the ESEA requires each LEA
receiving assistance under Title I to ensure that all paraprofessionals
hired after the date of enactment of the NCLB and working in a program
supported by Title I funds shall have A) completed at least 2 years of
study at an institution of higher education; B) obtained an associate's
(or higher) degree; or (C) met a rigorous standard of quality and can
demonstrate through a formal State or local academic assessment
knowledge of and the ability to assist in instructing reading, writing
and mathematics, reading readiness, writing readiness or mathematics
readiness, as appropriate. Section 1119(d) of the ESEA requires LEAs
receiving Title I funds to ensure that all paraprofessionals hired
before the date of enactment of NCLB, and working in a program supported
with Title I funds, shall not later than 4 years after the date of
enactment, satisfy the requirements.

[Further action required]{.underline}: The DC SEA must develop a current
list of paraprofessionals for each Title I school and their status
toward meeting the highly qualified requirements. The DC SEA must
provide ED with a copy of this list when developed.

[Finding (2)]{.underline}: The DC SEA has not ensured that all
paraprofessionals working in a program supported with Title I funds have
earned a secondary school diploma or its equivalent. According to DCPS's
November 2004 data, at that time 3 paraprofessionals indicated that they
had not completed high school.

[Citation]{.underline}: Section 1119(f) of the ESEA requires that all
paraprofessionals working in Title I programs, regardless of the
paraprofessional's hiring date, have earned a secondary school diploma
or its recognized equivalent.

[Further action required]{.underline}: The DC SEA must submit to ED
evidence that the DCPS has reviewed its existing records, determined if
the paraprofessionals without high school diplomas or its recognized
equivalent are stilled employed in programs supported with Title I
funds, are providing instructional support, and whether these
individuals now have a high school diploma or its recognized equivalent.
If there are paraprofessionals working with programs supported with
Title I funds that do not have a high school diploma or it recognized
equivalent, the DC SEA must submit evidence that the DCPS has taken
actions to ensure that all paraprofessionals working in programs
supported with Title I funds have a high school diploma or its
recognized equivalent at the beginning of the 2006-2007 school year.

Indicator 2.2 - The SEA has established a statewide system of support
that provides, or provides for, technical assistance to LEAs and schools
as required.

**[Finding]{.underline}**: The DC SEA does not have a statewide system
of support that meets the requirements of section 1117 of the ESEA. A
review of the DC SEA's evidence of its statewide system of support
indicated there is no organized system of delivering technical
assistance to schools and districts in need of improvement. Funding is
largely used to carry out the highly qualified requirements for teachers
and paraprofessionals. Charter school staff indicated that they only
received assistance related to NCLB compliance issues, particularly
completion of the LEA plan.

[Citation]{.underline}: Section 1117(a)(1-4) of the ESEA requires each
State to establish a statewide system of intensive and sustained support
and improvement for LEAs and schools receiving funds under Title I in
order to increase the opportunity for all students served by those
agencies and schools to meet the State's academic content standards and
student academic achievement standards. Section 1117(a)(2) establishes
the priorities of the statewide system, and requires the State to first
provide support and assistance to LEAs with schools subject to
corrective action under section 1116 and assist those schools, in
accordance with section 1116(b)(11), for which an LEA has failed to
carry out its responsibilities under paragraphs (7) and (8) of section
1116(b). Second, the State shall provide support and assistance to other
LEAs with schools identified as in need of improvement under section
1116(b); and third, provide support and assistance to other LEAs and
schools participating under Title I that need that support and
assistance.

[Further action required]{.underline}: The DC SEA must establish and
maintain a statewide system of support consistent with the requirements
in section 1117 of the ESEA. The DC SEA must provide to ED a plan and
detailed timeline for how it will develop a statewide system of support
that meets the requirements of 1117 and documentation of the system's
implementation once that occurs

Indicator 2.3 - The SEA ensures that the LEA and schools meet parental
notice requirements and parental involvement requirements.

**[Finding (1]{.underline}):** The DC SEA did not ensure that all
schools have established school-level

parental involvement policies and parent compacts. Sites visited used a
standard

parent/student handbook that did not include the required elements of
school-parent

compacts. Further, the DC SEA did not ensure that charter schools have
parent

compacts. The two charter schools visited by the ED team utilized a
standard

parent/student handbook for this purpose that did not include the
required components of

school-parent compacts.

[Citation]{.underline}: Section 1118(b)(1) of the ESEA requires each
school that receives Title I funds to jointly develop with and
distribute to parents of participating students a written parental
involvement policy, agreed on by the parents, that describes the means
for carrying out the requirements of items (c) through (f ) of this
section. Parents shall be notified of the policy in an understandable
and uniform format and, to the extent practicable, provided in a
language the parents can understand. The policy shall be made available
to the local community and updated periodically to meet the changing
needs of the parents and the school. Section 1118(d) of the ESEA
requires, as a component of the school-level parental involvement
policy, that each Title I school jointly develop with parents for all
children served by Title I, a school-parent compact that outlines how
parents, the entire school staff, and students will share the
responsibility for improved student academic achievement and the means
by which the school and parents will build and develop a partnership to
help children achieve the State's high standards.

[Further action required]{.underline}: The DC SEA must provide ED with a
detailed timeline for how it will ensure that each DCPS public school
and each charter school receiving Title I funds will develop a written
school parental involvement policy, and a school-parent compact as one
of its components. The DC SEA must ensure that the parental involvement
policies for the charter schools (that are also LEAs) address all the
requirements of 1118(b) and the appropriate provisions of
1118(a)---Local Educational Agency Policy. The DC SEA must provide ED
with a sample copy of a school-level policy and compact developed by one
of its public schools and a sample of a charter school parental
involvement policy and compact developed by one if its charter schools
(one copy for each category of school).

**[Finding (2)]{.underline}:** The DC SEA has not ensured that its LEAs
that receive at least \$500,000 in Title I funding reserve at least one
percent of their allocation for parental involvement activities and
allocate ninety-five percent of that to schools. DCPS has used the
reservation to fund four parent officers to serve as liaisons between
parents and schools and parents were not involved in this decision.

[Citation]{.underline}: Section 1118(a)(3) of the ESEA requires each LEA
to reserve not less than

one percent of the agency's Title I allocation to carry out this section
including promoting family literacy and parenting skills if such
agency's allocation under subpart 2 is \$500,000 or more. Section
1118(a)(3)(B) of the ESEA requires that parents of students receiving
services under Title I be involved in the decisions regarding how these
funds are allotted for parental involvement activities.

[Further action required]{.underline}: The DC SEA must submit to ED
copies of amended plans from DCPS and BTWPCS showing that the required
one percent set-side for parental involvement activities is being taken,
describing some of the activities it will be used for and how parents
are involved in determining how these funds are used.

**[Finding (3)]{.underline}**: The DC SEA has not ensured that DCPS has
conducted an annual evaluation of its parental involvement policy, and
made revisions, if necessary.

[Citation]{.underline}: Section 1118(a)(2)(E) of the ESEA requires that
the LEA conduct an annual evaluation of the content and effectiveness of
the parent involvement policy, and revise it, if necessary.

[Further action required]{.underline}: The DC SEA must ensure that DCPS
and all charter schools conduct an annual evaluation of their parental
involvement policy. The DC SEA must provide ED with documentation that
this has occurred.

Indicator 2.5 - The SEA ensures that requirements for public school
choice are met.

Indicator 2.6 - The SEA ensures that requirements for the provision of
supplemental educational services (SES) are met.

**[Recommendation]{.underline}**: The DC SEA maintains choice and
supplemental services participation data for Title I public schools
only. It does not maintain participation data for Title I charter
schools. ED recommends that the DC SEA maintain participation data
similarly for its charter schools.

Indicator 2.7 - The SEA ensures that LEAs and schools develop schoolwide
programs that use the flexibility provided to them by law to improve the
academic achievement of all students in the school.

**[Finding]{.underline}:** The DC SEA has not ensured that all school
improvement plans for schools also operating as schoolwide programs
contained the required 10 component required for schoolwide programs,
specifically early childhood transition to local elementary programs,
and strategies to attract highly qualified staff to high-need schools.

[Citation]{.underline}: Section 1114(b)(1)(A-J) of the ESEA requires a
schoolwide program to include the following components: 1) a
comprehensive needs assessment; 2) schoolwide reform strategies; 3)
instruction by highly qualified teachers; 4) high-quality and ongoing
professional development; 5) strategies to attract high-quality, highly
qualified teachers to high-need schools; 6) strategies to increase
parental involvement in accordance with section 1118 of the ESEA; 7)
plans for assisting preschool children in the transition from early
childhood programs, such as Head Start, Even Start, Early Reading First,
or a State-run preschool program to local elementary school programs; 8)
measures to include teachers in the decisions regarding the use of
academic assessments; 9) activities to ensure that students who
experience difficulty mastering the proficient or advanced levels of
academic achievement standards are provided with effective, timely
additional assistance; and 10) coordination and integration of Federal,
State and local services and programs.

[Further action required]{.underline}: The DC SEA must modify its school
improvement plan template to reflect the inclusion of all required
schoolwide program plan components, consistent with section
1114(b)(1)(A-J), for all schools that operate as schoolwide programs.
The DC SEA must submit to ED a copy of the modified template.

+-------+--------------------------------------------+---------+-----+
| **    |                                            |         |     |
| Monit |                                            |         |     |
| oring |                                            |         |     |
| Area  |                                            |         |     |
| 3,    |                                            |         |     |
| Title |                                            |         |     |
| I,    |                                            |         |     |
| Part  |                                            |         |     |
| A:    |                                            |         |     |
| Fidu  |                                            |         |     |
| ciary |                                            |         |     |
| Res   |                                            |         |     |
| ponsi |                                            |         |     |
| bilit |                                            |         |     |
| ies** |                                            |         |     |
+-------+--------------------------------------------+---------+-----+
| *     | # Description                              | **S     | **  |
| *Indi |                                            | tatus** | Pag |
| cator |                                            |         | e** |
| Num   |                                            |         |     |
| ber** |                                            |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.1   | SEA complies with---                       | Met     | ##  |
|       |                                            | requ    | ### |
|       | -   The procedures for adjusting           | irement | ### |
|       |     ED-determined allocations outlined in  |         |  NA |
|       |     sections 200.70 -- 200.75 of the       |         |     |
|       |     regulations.                           |         |     |
|       |                                            |         |     |
|       | -   The procedures for reserving funds for |         |     |
|       |     school improvement, State              |         |     |
|       |     administration, and (where applicable) |         |     |
|       |     the State Academic Achievement Awards  |         |     |
|       |     program.                               |         |     |
|       |                                            |         |     |
|       | -   The reallocation and carryover         |         |     |
|       |     provisions in section 1126(c) and 1127 |         |     |
|       |     of Title I statute.                    |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.2   | SEA ensures that its LEAs comply with the  | Finding | ##  |
|       | provision for submitting an annual         |         | ### |
|       | application to the SEA and revising LEA    |         | ### |
|       | plans as necessary to reflect substantial  |         |  14 |
|       | changes in the direction of the program.   |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.3   | SEA ensures that all its LEAs comply with  | Met     | ##  |
|       | the requirements in section 1113 of the    | requ    | ### |
|       | Title I Statute and sections 200.77 and    | irement | ### |
|       | 200.78 of the regulations with regard to   |         |  NA |
|       | (1) Reserving funds for the various        |         |     |
|       | set-asides either required or allowed      |         |     |
|       | under the statute, and (2) Allocating      |         |     |
|       | funds to eligible school attendance areas  |         |     |
|       | or schools in rank order of poverty based  |         |     |
|       | on the number of children from low-income  |         |     |
|       | families who reside in an eligible         |         |     |
|       | attendance area.                           |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.4   | -   SEA complies with the maintenance of   | Met     | ##  |
|       |     effort (MOE) provisions of             | requ    | ### |
|       |                                            | irement | ### |
|       | > Title I.                                 |         |  NA |
|       |                                            |         |     |
|       | -   SEA ensures that its LEAs comply with  |         |     |
|       |     the comparability provisions of Title  |         |     |
|       |     I.                                     |         |     |
|       |                                            |         |     |
|       | -   SEA ensures that Title I funds are     |         |     |
|       |     used only to supplement or increase    |         |     |
|       |     non-Federal sources used for the       |         |     |
|       |     education of participating children    |         |     |
|       |     and do not supplant funds from         |         |     |
|       |     non-Federal sources.                   |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.5   | SEA ensures that its LEAs comply with all  | Finding | 14  |
|       | the auditee responsibilities specified in  |         |     |
|       | Subpart C, section 300(a) through (f) of   |         |     |
|       | OMB Circular A-133.                        |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.6   | SEA ensures that its LEAs comply with      | F       | ##  |
|       | requirements regarding services to         | indings | ### |
|       | eligible private school children, their    |         | ### |
|       | teachers and families.                     |         |  15 |
+-------+--------------------------------------------+---------+-----+
| 3.7   | SEA complies with the requirement for      | Finding | ##  |
|       | implementing a system for ensuring prompt  |         | ### |
|       | resolution of complaints.                  |         | ### |
|       |                                            |         |  20 |
+-------+--------------------------------------------+---------+-----+
| 3.8   | SEA complies with the requirement to       | Finding | ##  |
|       | establish a Committee of Practitioners and |         | ### |
|       | involves the committee in decision-making  |         | ### |
|       | as required.                               |         |  21 |
+-------+--------------------------------------------+---------+-----+
| 3.9   | Equipment and Real Property. The SEA and   | F       | ##  |
|       | LEA must establish and implement controls  | indings | ### |
|       | over the procurement, recording, custody,  |         | ### |
|       | use, and disposition of Title I equipment  |         |  21 |
|       | in accordance with the provisions of State |         |     |
|       | policies and procedures, the NCLB, the     |         |     |
|       | Improper Payments Information Act,         |         |     |
|       | standards of internal control, and any     |         |     |
|       | other relevant standards, circulars, or    |         |     |
|       | legislative mandates                       |         |     |
+-------+--------------------------------------------+---------+-----+
| 3.10  | SEA and LEAs comply with requirements      | Met     | ##  |
|       | regarding procurement of goods and         | requ    | ### |
|       | services and the disbursement of Title I   | irement | ### |
|       | funds in accordance with State policies    |         |  NA |
|       | and procedures, NCLB, the Improper         |         |     |
|       | Payments Information Act, and any other    |         |     |
|       | relative standards, circulars, or          |         |     |
|       | legislative mandates.                      |         |     |
+-------+--------------------------------------------+---------+-----+

**Title I, Part A**

**Monitoring Area 3: Fiduciary Responsibilities**

## Indicator 3.2: LEA Plan

**[Finding]{.underline}:** The DC SEA has not ensured a timely plan
approval and release of Title I funds. Interviews with DCPS and LEA
charter school staff indicated that the LEA plan process was very
prolonged, burdensome, and problematic. Even though Title I funds were
available in October 2005, DCPS and LEA charter schools had received no
Title I funding at the time of the review conducted in March 2006. The
ED team was informed that DCPS and LEA charter schools must utilize
other funds to carry out all required activities under NCLB pending
receipt of their Title I allocation.

[Citation]{.underline}: Section 80.40(a) of the Education Department
General Administrative Regulations (EDGAR) requires that grantees are
responsible for managing the day-to-day operations of grant and subgrant
supported activities. Grantees must monitor grant and subgrant supported
activities to assure compliance with applicable Federal requirements and
that performance goals are being achieved. Grantee monitoring must cover
each program, function or activity.

[Further action required]{.underline}: The DC SEA must provide funding
to its LEAs in a timely manner after an LEA plan is received, reviewed,
and approved. The DC SEA must submit to ED evidence that DCPS and all
Title I charter schools have received their 2005-2006 Title I
allocation: The DC SEA must develop procedures to ensure the timely
reviews and approval of all LEA applications for the 2006-2007 school
year. The DC SEA must submit these procedures to ED, along with
documentation that its revised process has ensured timely plan approval
and funding of its LEA for the 2006-2007 school year.

Indicator 3.5 -- SEA ensures that its LEAs comply with all the auditee
responsibilities specified in Subpart C, section 300(a) through (f) of
OMB Circular A-133.

**[Finding]{.underline}:** The DC SEA has not ensured that corrective
action had been completed for Finding 04-12 in the 2004 A-133 audit. The
corrective action was scheduled to be completed March 1, 2006. The DC
SEA failed to ensure that corrective action steps that were the
responsibility of other functional areas were completed in a timely
manner.

[Citation]{.underline}: Section 80.26(b)(3) of EDGAR requires that
"State and local governments . . . that provide Federal awards to a sub
grantee, which expends \$300,000 or more (or other amount as specified
by OMB) in Federal awards in a fiscal year, . . . Ensure that
appropriate corrective action is taken within six months after receipt
of the audit report in instances of noncompliance with Federal laws and
regulations." OMB Circular A-133, Subpart D, Section \_\_\_\_.400(d)(5)
requires a pass-through entity to ". . . ensure that the sub recipient
takes appropriate and timely corrective action."

[Further action required]{.underline}: The DC SEA must provide a copy of
the procedures to process, track, and certify individuals charged to
Federal grants to ED. Additionally, the DC SEA must provide ED with a
copy of a process to ensure that all functional areas will complete
timely corrective actions inclusive of the name of the senior officer(s)
responsible to oversee compliance and monitoring.

**Indicator 3.6 -- The SEA ensures that its LEAs comply with the
requirements regarding services to eligible private school children,
their teachers and families.**

**[Finding (1)]{.underline}:** The DC SEA has not ensured that DCPS has
administered the Title I program in accordance with the statute and the
regulations. The ED team found that there is no oversight by the DC SEA
of DCPS' implementation of Title I programs for eligible private school
children, their teachers, and their families.

While DCPS is providing services to eligible private school children, it
is not fulfilling its role as the public agency responsible for
planning, designing, and implementing Title I programs that meet the
needs of private school participants. Instead, it has allowed the
private school officials to assume responsibility for these activities
such as analyzing needs of private school children, designing a program
with contractors to meet identified needs, directing contractors' work,
and designing professional development and parent involvement
activities.

[Citation]{.underline}: Section 80.40 of the Education Department
General Administrative Regulations (EDGAR) -- Grantees must monitor
grant and subgrant activities to ensure compliance with applicable
Federal requirements.

Section 9304 (a) of the ESEA requires that the SEA must ensure that (1)
programs authorized under ESEA are administered in accordance with all
applicable statutes, regulations, program plans, and applications; and
(2) the State will use fiscal control and funds accounting procedures
that will ensure the proper disbursement of and accounting for Federal
funds.

[Further action required]{.underline}: See further action required for
findings (2) through (7).

**[Finding (2)]{.underline}:** The DC SEA has not ensured that DCPS has
exercised proper administration (control) of the Title I services it is
responsible for providing to private school teachers and families of
participants. For example, Archdiocese of Washington staff members
negotiated directly with two contractors, to develop and plan
professional development and parental involvement activities. The scope
of work in both contracts include activities that are prohibited under
Title I, Part A because the activities benefit the needs of the private
schools, rather than those of the eligible private school students. The
principals in the private schools not affiliated with the Archdiocese
design and implement the professional development and parent involvement
activities at each individual school. DCPS staff members are not
involved in planning or implementing professional development and parent
involvement activities nor do they attend the planned activities to
ensure that the activities meet Title I requirements.

[Citation]{.underline}: Section 1120(a)(1) of the ESEA requires that the
LEA shall, after meaningful consultation with appropriate private school
officials, ensure that teachers and families of participants receive
equitable services. In addition, section 1120(d)(1) of the ESEA requires
the LEA to administer and maintain control of Title I funds.

Section 200.67 of the Title I regulations requires that an LEA must use
Title I funds to meet the educational needs of the private school
participants and the LEA may not use any Title I funds for the needs of
the private school or the general needs of children in the private
school.

[Further action required]{.underline}: The DC SEA must require that DCPS
exercise proper oversight for the Title I services it provides to
private school teachers and families of private school participants and
ensure that the third party provider who are providing these services
are not in violation of Title I requirements. The DC SEA must provide ED
with a detailed description of how and when it informed DCPS of these
requirements, what technical assistance it will provide to DCPS, how it
will monitor these requirements, and provide a copy of a third party
contract as evidence that the private schools do not benefit from the
Title I funded services. In addition, the DC SEA must require the DCPS
to articulate the policy basis, data, or criteria it used determine the
services provided to private school teachers and families of private
school participants and must provide this information to ED.

**[Finding (3)]{.underline}:** The DC SEA has not ensured that DCPS has
exercised proper oversight in awarding contracts for the provision of
Title I services to participating private school students. DCPS selected
two third party providers to provide services to participating private
school students. These two contracts with these providers reflect
supplemental educational services requirements instead of addressing the
requirements for serving eligible private school students. Two other
contracts did not have enough detail to enable DCPS to determine that
the Title I statutory and regulatory requirements will be met. There is
no evidence that any of the four contracts reflected the needs that
should have been identified by DCPS in consultation with private school
officials.

[Citation]{.underline}: Section 9306(a)(1) & (2) of the ESEA requires an
LEA when submitting a consolidated application to ensure that Title I
will be administered in accordance with all applicable rules,
regulations, program plans, and applications and the LEA will maintain
control of funds provided and title to any property acquired with Title
I funds will be in the LEA and the LEA will administer those funds and
property as required by Title I. Contracts must contain enough detail on
how the third party provider will implement Title I requirements with
detail sufficient to enable DCPS to determine that the Title I statutory
and regulatory requirements will be met.

[Further action required]{.underline}: The DC SEA must require DCPS to
ensure that the third parties are providing Title I services to eligible
private school children, their teachers, and their families in
accordance with all Title I requirements. In order for DCPS to exercise
proper oversight, the DC SEA must require DCPS to have signed contracts
or agreements with third party providers that provide technical
descriptions of the Title I services with such detail sufficient to
enable DCPS to determine that the Title I statutory and regulatory
requirements will be met as required by section 9306 of the ESEA. The DC
SEA must provide ED with a detailed description of how and when it
informed DCPS of this requirement, what technical assistance it will
provide to DCPS, how it will monitor this requirement, and a copy of one
contract that meets this requirement.

**[Finding (4)]{.underline}:** The DC SEA has not ensured that DCPS has
exercised proper oversight when reimbursing third party providers for
services to private school students. Invoices submitted by third party
providers contained very little detail on the expenditures listed and
did not separate charges for instruction and administration. In on case,
documentation provided to ED included an invoice from a provider of
parent involvement activities that DCPS paid with Title I funds. The
invoice covered expenditures incurred to develop with private school
principals a student behavior handbook for every child attending the
private schools, an activity that is not allowable.

[Citation]{.underline}: Section 9306(a)(5) of the ESEA requires an LEA
when submitting a consolidated application to use fiscal control and
fund accounting procedures that will ensure proper disbursement of, and
accounting for, Federal funds paid to the LEA.

Section 443 of the General Education Provisions Act (GEPA) requires each
recipient of Federal funds such as an LEA to keep records which fully
disclose the amount and disposition of the funds, the total costs of the
activity for which the funds are used ... and such other records as will
facilitate an effective financial or programmatic audit.

Section 1120(a)(3) of the ESEA, requires that funds generated by private
school children must be used for instructional activities if the funds
generated by public school children from low-income families are used
for instructional activities.

[Further action required]{.underline}: The DC SEA must provide ED with a
detailed description of the steps it will take to ensure that the DCPS
to exercise proper oversight over invoices submitted from third party
providers that are providing Title I services to private school
students. Providers must list on their invoices expenditures in at least
two categories: instructional activities (paid with funds generated by
children from low-income families) and administration costs (paid with
funds from the section 200.77(f) reservations). Within each category,
the contractors must provide detail sufficient to enable the LEA to
determine that the requested invoices are in accordance with Title I
requirements and the GEPA. Information could include the name and salary
of each teacher, the instructional materials purchased, and the specific
administrative costs such as supervisor's salary, office expenses,
travel costs, capital expense type costs, and fees. LEAs have the
authority under the GEPA to require documentation to support requested
expenditures.

The description must address the technical assistance the DC SEA will
provide to DCPS and how it will monitor the DCPS's oversight of
invoices.

**[Finding (5)]{.underline}:** The DC SEA has not ensured that the DCPS
uses Title I funds to pay for only allowable activities. Documentation
provided to ED included an invoice from a provider of parent involvement
activities that DCPS paid with Title I funds. The invoice covered
expenditures incurred to develop with private school principals, a
student behavior handbook for every child attending the private schools.

[Citation]{.underline}: Section 200.67 of the Title I regulations
requires that an LEA must use Title I funds to meet the educational
needs of the private school participants and the LEA may not use any
Title I funds for the needs of the private school or the general needs
of children in the private school.

[Further action required]{.underline}: The DC SEA must provide ED with a
detailed description of the steps it will take to ensure that the DCPS
does not use Title I funds to pay for activities that are prohibited
under the ESEA. The description must address the technical assistance
the DC SEA will provide to DCPS and how it will monitor the DCPS'
compliance with 200.67.

[Finding (6)]{.underline}: The DC SEA informed the team that it does not
collect the required affirmation forms annually.

[Citation]{.underline}: Section 1120(b)(4) of the ESEA requires each LEA
to maintain and provide to the SEA a written affirmation signed by the
officials of each participating private school that the required
consultation has occurred.

[Further action required]{.underline}: The DC SEA must require DCPS to
forward to the DC SEA annually documentation such as written affirmation
forms signed by private school officials (or their representative) that
the required consultation has occurred. The DC SEA must provide ED with
a detailed description of the process, including dates that it will use
to collect this documentation that the required consultation has
occurred.

**[Finding (7)]{.underline}:** The DC SEA has not ensured that DCPS, in
consultation with private school officials, has established multiple,
educationally related, objective criteria to identify private school
students for Title I services. DCPS has no documented process for the
selection of students from the private schools. It appears that each
private school selects students using different criteria. Students are
selected in one school using the 55^th^ percentile test score as the cut
off score; in another school, the 35^th^ percentile is used. Although
teachers recommend participants, DCPS has no form that the private
school classroom teachers use to recommend students so that there is
consistency from one teacher to another. In addition, parents may also
ask that their child receive services. Any child who meets only one
criterion and is determined by DCPS to be address eligible is selected
to participate by the private school officials who give the names of the
participants to the contractors. As a result, DCPS has not determined
which private school children from the eligible pool are those who are
most at risk. Thus, the Title I programs are not designed to meet the
needs of the participants who are most at risk.

Additionally, DCPS has not established, in consultation with the private
schools, procedures for adding to or exiting students from the Title I
program.

[Citation]{.underline}: Section 1120(a) of the ESEA requires that LEAs
must provide Title I services to eligible children who are enrolled in
elementary and secondary private schools. Section 200.62(b)(1) & (2) of
the Title I regulations states that eligible private school children are
children who reside in participating public school attendance areas and
meet the criteria in section 1115(b) of the ESEA. Among the eligible
children, the LEA must select children to participate in accordance with
section 200.64.

[Further action required]{.underline}: The DC SEA must provide ED with
evidence that it has provided guidance on the selection of private
school students to DCPS regarding the selection of students. The DC SEA
must provide ED with a detailed description of how and when it informed
DCPS of this requirement. The DC SEA must also provide ED with a copy of
the criteria that DCPS has determined, in consultation with private
school officials, it will use select private school students for Title I
services for the 2006- 2007 school year. The DC SEA must also provide ED
with a description of how it will ensure the correct implementation of
this requirement.

**[Finding (8)]{.underline}:** The DC SEA has not ensured that DCPS has
met the requirements for evaluation of the Title I program for private
school students including what constitutes annual progress for the Title
I programs serving private school participants. Although pre and post
tests are administered by the third party providers, and some private
school staff members review individual student data, DCPS has not
determined, in consultation with private school officials, how the Title
I program that is provided to private school students will be assessed,
what the agreed upon standards are, and how the annual progress will be
measured.

[Citation]{.underline}: Section 1120(b)(1)(D) of the ESEA and section
200.63 (b)(5) of the Title I regulations require an LEA to consult with
appropriate officials from private schools during the design and
development of the LEA's program for eligible private school students on
issues such as how the LEA will assess academically the services to
eligible private school students and how the LEA will use the results of
that assessment to improve Title I services.

[Further action required]{.underline}: The DC SEA must ensure that DCPS,
as part of the consultation process, makes a determination as to what
standards and assessments will be used to measure the annual progress of
the Title I programs provided private school participants. The DC SEA
must provide ED with a detailed description of how and when the DC SEA
informed DCPS of this requirement, what technical assistance it will
provide to DCPS, and how it will monitor this requirement to ensure that
the Title I programs provide reasonable promise that the private school
participants will achieve to high levels.

**[Recommendation]{.underline}**: Title I services are being provided
for students who have been placed at the Psychiatric Institute of
Washington. The courts have adjudicated some

students; others have been placed at this facility by either a district
agency or parents. The length of stay varies from several weeks to
several months. DCPS should investigate the possibility of identifying
this facility as an institution for neglected students rather than a
private school.

**Indicator 3.7 -- The SEA complies with the requirement for
implementing a system for the prompt resolution of complaint.**

**[Finding (1)]{.underline}:** The DC SEA has not ensured that its LEAs
have copies of its complaint procedures. Interviews with charter school
officials indicated they did not have a copy of any complaint procedure,
nor were they aware of any complaint policy and procedure. Further, DCPS
officials informed the ED team that its complaint procedures require
DCPS, not the DC SEA, to resolve all complaints.

[Citation]{.underline}: Section 9304(a)(3)(C) of the ESEA requires
States to adopt written procedures for the receipt and resolution of
complaints alleging violations of law in the administration of programs.
This provision is required under the general applicability of State
educational agency assurances, whereby a State educational agency, in
consultation with the Governor of the State, that submits a consolidated
State plan or consolidated State application, shall have on file with
the Secretary a single set of assurances, applicable to each program for
which the plan or application is submitted

[Further action required]{.underline}: The DC SEA must provide to all
its LEAs a copy of the written procedures for the receipt and resolution
of complaints, and provide ED with a description of how and when this
information was disseminated.

Indicator 3.8 -- The SEA complies with the requirement to establish a
Committee of Practitioners and involves the committee in decision making
as required.

**[Finding]{.underline}:** The DC SEA did not ensure that its committee
of practitioners (COP) was in compliance with the membership
requirements of the ESEA, was carrying out required duties specified in
the ESEA, or was otherwise currently active. The DC SEA indicated that
the COP is currently being reconstituted in order to address both
Federal and State requirements.

[Citation]{.underline}: Section 1903(b) of the ESEA requires each SEA
that receives funds under

Title I to create a State committee of practitioners to advise the State
in carrying out its responsibilities and specifies what the requirements
shall be for membership in the COP and what duties shall be included.

[Further action required]{.underline}: The DC SEA must complete the
process for the full development of a COP that is in compliance with
sections 1903(b) and 1111(c)(11). The DC SEA must submit to ED a roster
of the COP's membership upon completion.

**Indicator 3.9 -- Equipment and real property**

**[Finding (1)]{.underline}:** The DC SEA did not provide an equipment
list that included date of purchase.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must provide to ED
documentation showing the date of purchase for each item on its current
List of Equipment Assets.

**[Finding (2)]{.underline}:** The DC SEA does not maintain adequate
controls to account for procurement, location, custody, and security of
equipment purchased with Title I funds. Six (19 percent) of the
equipment items selected for inspection from the equipment list provided
by the DC SEA were unavailable for inspection.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."
Section 443 of the GEPA requires each recipient of Federal funds, such
as an LEA, to keep records, which fully disclose the amount and
disposition of the funds, the total costs of the activity for which the
funds are used . . . and such other records as will facilitate an
effective financial or programmatic audit.

[Further action required]{.underline}: The DC SEA must implement and
maintain adequate controls to account for the procurement, location,
custody, and security of equipment purchased with Title I funds. The DC
SEA must provide to ED a copy of a corrective action plan to address
this requirement which, when fully implemented, will ensure that
adequate controls are maintained to account for procurement, location,
custody, and security of equipment purchased with Title I funds.

**[Finding (3)]{.underline}:** The DC SEA was unable to locate a \$9,950
application of software for mainframe, Property-Sfx OGA9202217-00.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."
Section 443 of the GEPA requires each recipient of Federal funds, such
as an LEA, to keep records, which fully disclose the amount and
disposition of the funds, the total costs of the activity for which the
funds are used . . . and such other records as will facilitate an
effective financial or programmatic audit.

[Further action required]{.underline}: The DC SEA must implement and
maintain adequate controls to account for the procurement, location,
custody, and security of equipment purchased with Title I funds. The DC
SEA must provide to ED a copy of a corrective action plan to address
this requirement which, when fully implemented, will ensure that
adequate controls are maintained to account for procurement, location,
custody, and security of equipment purchased with Title I funds.

**[Finding (4)]{.underline}:** At the DC SEA, two (1 percent) of the
equipment items tested did not include an Asset ID tag. The property
description of both items was NX5000 PM/1500 512MB 40GB DVD/CDRW. The
Property-Sfx numbers were OGA9202295-01 and OGA9202295-03.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must implement and
maintain adequate controls to account for the procurement, location,
custody, and security of equipment purchased with Title I funds. DCPS
must provide ED with a copy of a corrective action plan to address this
requirement.

**[Finding (5)]{.underline}:** The DC SEA did not ensure that the Amidon
Elementary School (AES) maintained and implemented adequate controls to
account for procurement, location, custody, disposal, and security of
Equipment/Inventory purchased with Title I funds. The equipment list at
the AES contained a "Credenza Unit Wood" twice on the listing. The items
had the same Property-Sfx number on the listing.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must ensure that all
LEAs implement and maintain adequate controls to account for the
procurement, location, custody, and security of equipment purchased with
Title I funds. The DC SEA must provide to ED a copy of a corrective
action plan to address this requirement inclusive of documentation of
communication of the planned actions to all LEAs and a follow-up plan to
monitor compliance.

**[Finding (6)]{.underline}:** The DC SEA did not ensure that the AES
maintained adequate internal controls to account for computer equipment
purchased with Title I funds. The school has a Title I computer lab
containing various computer (and related) equipment. None of this
equipment was listed on the inventory listing provided by the DC SEA.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must ensure that all
LEAs implement and maintain adequate controls to account for the
procurement, location, custody, and security of equipment purchased with
Title I funds. The DC SEA must provide to ED a copy of a corrective
action plan to address this requirement inclusive of documentation of
communication of the planned actions to all LEAs and a follow-up plan to
monitor compliance.

**[Finding (7)]{.underline}:** The DC SEA did not ensure the proper
labeling of equipment at Springarn High School (SHS). The Asset ID tag
and "Title I" label were placed on the tower holding the server and not
on the actual software package.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must ensure that the
SHS has adequate controls over its Title I equipment. The DC SEA must
provide to ED a copy of a corrective action plan to address this
requirement inclusive of a follow-up plan to monitor.

**[Finding (8)]{.underline}:** The DC SEA did not ensure a product or
documentation for a \$92,309 software package at the Ballou High School
(BHS). No product or documentation was provided the ED team.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."
Section 443 of the GEPA requires each recipient of Federal funds, such
as an LEA, to keep records, which fully disclose the amount and
disposition of the funds, the total costs of the activity for which the
funds are used . . . and such other records as will facilitate an
effective financial or programmatic audit.

[Further action required]{.underline}: The DC SEA must ensure that all
LEAs implement and maintain adequate controls to account for the
procurement, location, custody, and security of equipment purchased with
Title I funds. The DC SEA must provide ED with a copy of a corrective
action plan to address this requirement inclusive of documentation of
communication of the planned actions to all LEAs and a follow-up plan to
monitor compliance.

**[Finding (9)]{.underline}:** The DC SEA did not ensure that the BTWPCS
had policies and procedures to address the procurement, custody, use,
and disposition of Title I equipment. The school was unable to provide
policies and procedures in these areas.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must distribute to the
BTWPCS written policies and procedures that address the procurement,
custody, use, and disposition of Title I equipment. The DC SEA must
provide a copy of these policies and procedures to ED inclusive of
documentation of communication of the planned actions to BTWPCS and a
follow-up plan to monitor compliance.

**[Finding (10)]{.underline}:** The DC SEA did not ensure that the
BTWPCS maintained a current inventory of equipment. The equipment list
provided to the ED team did not include any equipment items purchased
with Title I funds. The inventory listing did not provide location, tag
or barcode number for any of the 25 items selected for testing.
Moreover, there were no tag or barcode numbers on the individual items
of equipment.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."

[Further action required]{.underline}: The DC SEA must ensure that all
of its LEAs maintain an up-to-date and comprehensive list of equipment
paid for with Title I funds, in accordance with a documented policy for
the procurement, recording, disposition, and physical inventory of Title
I equipment. Also, the DC SEA must make certain that LEAs are using bar
code numbers or an alternative means of identifying Title I equipment.
Documentation demonstrating a plan for compliance with these issues must
be provided to ED.

**[Finding (11)]{.underline}:** The DC SEA did not ensure that the SBPCS
maintained adequate internal controls to account for procurement,
location, custody, and security of equipment. The inventory list
provided the ED team did not include any equipment items purchased with
Title I funds. Also, the listing did not provide for cost or date of
purchase. The school was unable to locate 8 (40 percent) of the items of
equipment selected for test.

[Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State
\[LEA\] . . . use, manage and dispose of equipment acquired under a
grant by the State in accordance with State laws and procedures."
Section 443 of the General Education Provisions Act (GEPA) requires each
recipient of Federal funds, such as an LEA, to keep records, which fully
disclose the amount and disposition of the funds, the total costs of the
activity for which the funds are used . . . and such other records as
will facilitate an effective financial or programmatic audit.

[Further action required]{.underline}: The DC SEA must ensure that the
SBPCS maintains an up-to-date and comprehensive list of equipment paid
for with Title I funds, in accordance with a documented policy for the
procurement, recording, disposition, and physical inventory of Title I
equipment. Documentation demonstrating a plan to ensure compliance must
be provided to ED.

**[Finding (12)]{.underline}:** The DC SEA did not ensure that DCPS
maintained adequate controls to account for location, custody, and
security of, and maintained a comprehensive, accurate, and current
inventory of equipment purchased with Title I funds located in the
private schools. DCPS could not provide ED with a list of Title I
purchased equipment by private school. At the private school, ED staff
observed that materials and equipment purchased with Title I funds were
not labeled and in one instance, the private school principal of the
private school indicated that she had received the labels from DCPS, and
had attached the labels.

[Citation]{.underline}: State and local government requirements for
equipment are set forth in section 80.32(d) of EDGAR, which requires
that a control system must be developed that ensures adequate safeguards
to prevent loss, damage, or theft of the property. These controls are
essential given that the property is located in space at private school
sites and there can be misuse of the equipment and property by the
private school officials if improperly labeled. The LEA is required
under section 1120(d)(1) of the ESEA to administer all property
purchased with Title I funds.

## 

[Further action required]{.underline}: The DC SEA must require DCPS to
establish a control system for properly tagging all property and
equipment purchased with Title I funds and located at private school
sites with the words "Property of DC Public Schools" placed on labels
that cannot be either erased and/or removed. The DC SEA must provide to
ED a copy of a corrective action plan to address this requirement
including a follow-up plan to monitor compliance.

# Summary of Title I, Part B, Subpart 3 (Even Start) Monitoring Indicators

# 

+--------+---------------------------------------+--------------+-----+
| # M    |                                       |              |     |
| onitor |                                       |              |     |
| ing Ar |                                       |              |     |
| ea 1,  |                                       |              |     |
| Title  |                                       |              |     |
| I, Par |                                       |              |     |
| t B, S |                                       |              |     |
| ubpart |                                       |              |     |
|  3: Ac |                                       |              |     |
| counta |                                       |              |     |
| bility |                                       |              |     |
+--------+---------------------------------------+--------------+-----+
| **Ind  | **Description**                       | # Status     | #   |
| icator |                                       |              |  Pa |
| Nu     |                                       |              | ge  |
| mber** |                                       |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.1    | The SEA complies with the subgrant    | Met          | 31  |
|        | award requirements.                   | requirement  |     |
|        |                                       |              |     |
|        |                                       | Rec          |     |
|        |                                       | ommendations |     |
+--------+---------------------------------------+--------------+-----+
| 1.2    | The SEA requires applicants to submit | Finding      | 32  |
|        | applications for subgrants with the   |              |     |
|        | necessary documentation.              |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.3    | In making non-competitive             | Met          | NA  |
|        | continuation awards, the SEA reviews  | requirement  |     |
|        | the progress of each subgrantee in    |              |     |
|        | meeting the objectives of the program |              |     |
|        | and evaluates the program based on    |              |     |
|        | the Indicators of Program Quality.    |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.4    | The SEA refuses to award subgrant     | Met          | 32  |
|        | funds to an eligible entity if the    | requirement  |     |
|        | agency finds that the entity has not  |              |     |
|        | sufficiently improved the performance | Re           |     |
|        | of the program, as evaluated, based   | commendation |     |
|        | on the Indicators of Program Quality. |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.5    | The SEA develops, based on the best   | Met          | NA  |
|        | available research and evaluation     | requirement  |     |
|        | data, Indicators of Program Quality   |              |     |
|        | for Even Start programs.              |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.6    | The SEA uses the Indicators of        | Met          | NA  |
|        | Program Quality to monitor, evaluate, | requirement  |     |
|        | and improve local programs within the |              |     |
|        | State.                                |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.7    | The SEA conducts monitoring of its    | Met          | NA  |
|        | subgrantees sufficient to ensure      | requirement  |     |
|        | compliance with Even Start program    |              |     |
|        | requirements.                         |              |     |
+--------+---------------------------------------+--------------+-----+
| 1.8    | The SEA ensures that projects provide | Met          | NA  |
|        | for an independent local evaluation   | requirement  |     |
|        | of the program that is used for       |              |     |
|        | program improvement.                  |              |     |
+--------+---------------------------------------+--------------+-----+

+--------+---------------------------------------+-------------+------+
| ## Mo  |                                       |             |      |
| nitori |                                       |             |      |
| ng Are |                                       |             |      |
| a 2, T |                                       |             |      |
| itle I |                                       |             |      |
| , Part |                                       |             |      |
|  B, Su |                                       |             |      |
| bpart  |                                       |             |      |
| 3: Ins |                                       |             |      |
| tructi |                                       |             |      |
| onal S |                                       |             |      |
| upport |                                       |             |      |
+========+=======================================+=============+======+
| **Ind  | # Description                         | ### Status  | ##   |
| icator |                                       |             | Page |
| Nu     |                                       |             |      |
| mber** |                                       |             |      |
+--------+---------------------------------------+-------------+------+
| 2.1    | The SEA uses funds to provide         | Met         | NA   |
|        | technical assistance to local         | requirement |      |
|        | programs to improve the quality of    |             |      |
|        | Even Start family literacy services.  |             |      |
+--------+---------------------------------------+-------------+------+
| 2.2    | Each program assisted shall include   | Met         | NA   |
|        | the identification and recruitment of | requirement |      |
|        | families most in need, and serve      |             |      |
|        | those families.                       |             |      |
+--------+---------------------------------------+-------------+------+
| 2.3    | Each program shall include screening  | Met         | NA   |
|        | and preparation of parents and enable | requirement |      |
|        | those parents and children to         |             |      |
|        | participate fully in the activities   |             |      |
|        | and services provided.                |             |      |
+--------+---------------------------------------+-------------+------+
| 2.4    | Families are participating in all     | Met         | NA   |
|        | four core instructional services.     | requirement |      |
+--------+---------------------------------------+-------------+------+
| 2.5    | Each program shall be designed to     | Met         | NA   |
|        | accommodate the participants' work    | requirement |      |
|        | schedule and other responsibilities,  |             |      |
|        | including the provision of support    |             |      |
|        | services, when those services are     |             |      |
|        | unavailable from other sources.       |             |      |
+--------+---------------------------------------+-------------+------+
| 2.6    | Each program shall include            | Met         | NA   |
|        | high-quality, intensive instructional | requirement |      |
|        | programs that promote adult literacy  |             |      |
|        | and empower parents to support the    |             |      |
|        | educational growth of their children, |             |      |
|        | and in preparation of children for    |             |      |
|        | success in regular school programs.   |             |      |
+--------+---------------------------------------+-------------+------+
| 2.7    | All instructional staff of the        | Met         | NA   |
|        | program hired after enactment of the  | requirement |      |
|        | LIFT Act (December 21, 2000), whose   |             |      |
|        | salaries are paid in whole or in part |             |      |
|        | with Even Start funds, meet the Even  |             |      |
|        | Start staff qualification             |             |      |
|        | requirements.                         |             |      |
+--------+---------------------------------------+-------------+------+
| 2.8    | By December 21, 2004, a majority of   | Met         | NA   |
|        | the individuals providing academic    | requirement |      |
|        | instruction shall have obtained an    |             |      |
|        | associate's, bachelors, or graduate   |             |      |
|        | degree in a field related to early    |             |      |
|        | childhood education, elementary       |             |      |
|        | school or secondary school education, |             |      |
|        | or adult education.                   |             |      |
+--------+---------------------------------------+-------------+------+
| 2.9    | By December 21, 2004, if applicable,  | Met         | NA   |
|        | a majority of the individuals         | requirement |      |
|        | providing academic instruction shall  |             |      |
|        | meet the qualifications established   |             |      |
|        | by the [State]{.underline} for early  |             |      |
|        | childhood education, elementary or    |             |      |
|        | secondary education, or adult         |             |      |
|        | education provided as part of an Even |             |      |
|        | Start program or another family       |             |      |
|        | literacy program.                     |             |      |
+--------+---------------------------------------+-------------+------+
| 2.10   | By December 21, 2004, the person      | Met         | NA   |
|        | responsible for administration of     | requirement |      |
|        | family literacy services has received |             |      |
|        | training in the operation of a family |             |      |
|        | literacy program.                     |             |      |
+--------+---------------------------------------+-------------+------+
| 2.11   | By December 21, 2004,                 | Met         | NA   |
|        | paraprofessionals who provide support | requirement |      |
|        | for academic instruction have a       |             |      |
|        | secondary school diploma or its       |             |      |
|        | recognized equivalent.                |             |      |
+--------+---------------------------------------+-------------+------+
| 2.12   | The local programs shall include      | Met         | NA   |
|        | special training of staff, including  | requirement |      |
|        | child-care workers, to develop the    |             |      |
|        | necessary skills to work with parents |             |      |
|        | and young children.                   |             |      |
+--------+---------------------------------------+-------------+------+
| 2.13   | The local programs shall provide and  | Met         | NA   |
|        | monitor integrated instructional      | requirement |      |
|        | services to participating parents and |             |      |
|        | children through home-based programs. |             |      |
+--------+---------------------------------------+-------------+------+
| 2.14   | The local programs shall operate on a | Met         | NA   |
|        | year-round basis, including the       | requirement |      |
|        | provision of some program services,   |             |      |
|        | including instructional and           |             |      |
|        | enrichment services, during the       |             |      |
|        | summer months.                        |             |      |
+--------+---------------------------------------+-------------+------+
| 2.15   | The local program shall be            | Met         | NA   |
|        | coordinated with other relevant       | requirement |      |
|        | programs under the Adult Education    |             |      |
|        | and Family Literacy Act, the          |             |      |
|        | Individuals with Disabilities Act,    |             |      |
|        | and Title I of the Workforce          |             |      |
|        | Investment Act of 1988, and the Head  |             |      |
|        | Start program, volunteer literacy     |             |      |
|        | programs, and other relevant          |             |      |
|        | programs.                             |             |      |
+--------+---------------------------------------+-------------+------+
| 2.16   | The local programs shall use          | Met         | NA   |
|        | instructional programs based on       | requirement |      |
|        | scientifically based reading research |             |      |
|        | for children and adults.              |             |      |
+--------+---------------------------------------+-------------+------+
| 2.17   | The local program shall encourage     | Met         | NA   |
|        | participating families to attend      | requirement |      |
|        | regularly and to remain in the        |             |      |
|        | program a sufficient time to meet     |             |      |
|        | their program goals.                  |             |      |
+--------+---------------------------------------+-------------+------+
| 2.18   | The local programs shall use          | Met         | NA   |
|        | reading-readiness activities for      | requirement |      |
|        | preschool children based on           |             |      |
|        | scientifically based reading          |             |      |
|        | research.                             |             |      |
+--------+---------------------------------------+-------------+------+
| 2.19   | The local program shall, if           | Met         | NA   |
|        | applicable, promote the continuity of | requirement |      |
|        | family literacy to ensure that        |             |      |
|        | individuals retain and improve their  |             |      |
|        | educational outcomes.                 |             |      |
+--------+---------------------------------------+-------------+------+

+-------+---------------------------------------+-------------+------+
| # M   |                                       |             |      |
| onito |                                       |             |      |
| ring  |                                       |             |      |
| Area  |                                       |             |      |
| 3, Ti |                                       |             |      |
| tle I |                                       |             |      |
|  Part |                                       |             |      |
|  B, S |                                       |             |      |
| ubpar |                                       |             |      |
| t 3:  |                                       |             |      |
| SEA F |                                       |             |      |
| iduci |                                       |             |      |
| ary R |                                       |             |      |
| espon |                                       |             |      |
| sibil |                                       |             |      |
| ities |                                       |             |      |
+-------+---------------------------------------+-------------+------+
| *     | # Description                         | ### Status  | ##   |
| *Indi |                                       |             | Page |
| cator |                                       |             |      |
| Num   |                                       |             |      |
| ber** |                                       |             |      |
+-------+---------------------------------------+-------------+------+
| 3.1   | The SEA complies with the allocation  | Met         | NA   |
|       | requirements for State administration | requirement |      |
|       | and technical assistance and award of |             |      |
|       | subgrants.                            |             |      |
+-------+---------------------------------------+-------------+------+
| 3.2   | The SEA ensures that subgrantees      | Met         | 34   |
|       | comply with statutory and regulatory  | requirement |      |
|       | requirements on uses of funds and     |             |      |
|       | matching.                             | Rec         |      |
|       |                                       | ommendation |      |
+-------+---------------------------------------+-------------+------+
| 3.3   | The SEA complies with the             | Met         | NA   |
|       | cross-cutting maintenance of effort   | requirement |      |
|       | provisions.                           |             |      |
+-------+---------------------------------------+-------------+------+
| 3.4   | The SEA ensures timely and meaningful | Met         | NA   |
|       | consultation with private school      | requirement |      |
|       | officials on how to provide Even      |             |      |
|       | Start services and benefits to        |             |      |
|       | eligible elementary and secondary     |             |      |
|       | school students attending non-public  |             |      |
|       | schools and their teachers or other   |             |      |
|       | instructional personnel, and local    |             |      |
|       | programs provide an appropriate       |             |      |
|       | amount of those services and benefits |             |      |
|       | through an eligible provider.         |             |      |
+-------+---------------------------------------+-------------+------+
| 3.5   | The SEA has a system for ensuring     | Met         | NA   |
|       | fair and prompt resolution of         | requirement |      |
|       | complaints and appropriate hearing    |             |      |
|       | procedures.                           |             |      |
+-------+---------------------------------------+-------------+------+

**Title I, Part B, Subpart 3 (Even Start)**

**Monitoring Area 1: Accountability**

**Indicator 1.1 -- The SEA complies with the subgrants award
requirements.**

**[Recommendation]{.underline}:** It is not clear that the DC SEA is
applying the statutory priority for projects located in empowerment
zones or enterprise communities. ED recommends that the DC SEA indicate
in its request for proposals (RFP) that priority is given to projects
located in empowerment zones or enterprise communities.

**[Recommendation]{.underline}:** The RFP (p.19) incorrectly states that
projects are limited to eight years of funding. ED recommends that the
RFP remove this statement as the statutory limitation on the number of
years a project may receive Even Start funding is no longer applicable.

**[Recommendation]{.underline}:** The definition of eligibility in the
RFP does not include adults who are attending secondary school. The
citation and definition of "parent" in the RFP is incorrect. The RFP
must be revised to include the correct definition of adults and to
include adults who are attending secondary school when defining
participant eligibility.

**[Recommendation]{.underline}:** The RFP incorrectly states the
determination of most-in-need for participating adults. The RFP
indicates that either poverty or education may be used as the
determining factor for most in need when poverty and level of education
must be used. While these was no evidence that the families being served
by the projects were not most in need, ED recommends that the DC SEA's
RFP be revised to include the correct definition of most in need.

**[Recommendation]{.underline}:** ED recommends that the DC SEA include
the Federal minimum suggestions for hours of intensity for each core
area of Even Start in the RFP, as this information is not included in
the current RFP.

**[Recommendation]{.underline}:** The DC SEA must revise the RFP to
include the correct statutory citation describing staff qualifications
and include the requirements for the majority of Even Start-paid staff,
the administrative person, and paraprofessionals. The current RFP
includes an incorrect statutory citation describing staff
qualifications. Section (n) is missing the requirement related to the
majority of Even Start-paid staff. The RFP omits the requirements for
the administrative person and paraprofessionals.

**[Recommendation]{.underline}:** ED recommends that the DC SEA revise
the current RFP to include scientifically-based reading research as one
of the required program elements. The monitoring instrument should also
refer to a scientifically based curriculum rather than a developmentally
appropriate curriculum. Scientifically based reading research is missing
in the current RFP's list of required program elements. The monitoring
instrument refers to "developmentally appropriate" curriculum.

# Indicator 1.2 - The SEA requires applicants to submit applications for subgrants with the necessary documentation.

**[Finding]{.underline}:** Some of the required 15 program elements of
Even Start are missing from the RFP (RFP, pp. 19 -- 25): staff
qualifications for administrative person and paraprofessionals;
home-based programs; continuity; and serving most-in-need participants.
The list of the 15 required program elements (section 1235) in
Attachment L in the RFP omits the following required program elements
(home-based programs; coordination; continuity of family literacy;
serving most-in-need families (in contrast to recruiting/screening those
families); and independent evaluation.

[Citation]{.underline}: Section 1235 of the ESEA identifies the 15
required program elements for the Even Start program. Those elements
are: Identification and Recruitment of Families Most In Need of Even
Start Services; Screening and Preparation of Participants; Flexible
Scheduling and Support Services; High-Quality, Intensive Instructional
Services; Staff Qualifications; Staff Training; Home-Based Instructional
Services; Year-Round Services; Coordination with Other Programs;
Instructional Programs Based on Scientifically Based Reading Research;
Attendance and Retention; Reading Readiness Activities Based on
Scientifically Based Reading Research; Continuity of Services; Providing
Services to Families Most In Need; Local Independent Evaluation.

[Further action required]{.underline}: The DC SEA must correct the RFP
to include all required program elements in the RFP as well as
Attachment L of the RFP. The DC SEA must send a copy of the corrected
document to ED.

Indicator 1.4 -- The SEA develops, based on the best available research
and evaluation data, indicators of program quality for Even Start
programs, and uses the Indicators to monitor, evaluate, and improve
projects within the State. The SEA ensures compliance with Even Start
program requirements.

**[Recommendation]{.underline}:** Although the DC SEA uses State
indicators during monitoring to determine whether a project has made
sufficient progress, the DC SEA has not defined insufficient progress in
the RFP. It is recommended that the DC SEA consider having a definition
of insufficient progress to share with local projects. It is also
recommended that this definition be added to the RFP for non-competitive
continuation awards.

## 

## 

## 

## 

##   

## Monitoring Area 3: Fiduciary

Indicator 3.2 -- The SEA ensures that subgrantees comply with statutory
and regulatory requirements on uses of funds and matching.

**[Recommendation]{.underline}:** The application for the Family Place,
Inc. states that it will use funds for holiday parties although there is
no evidence that the project has done so. ED recommends that the DC SEA
inform the Family Place Inc. that entertainment is not an allowable use
of Even Start funds, although they can hold literacy-related award
ceremonies.

# Summary of Title I, Part D Monitoring Indicators

+---------+-------------------------------------+--------------+------+
| #       |                                     |              |      |
| Neglect |                                     |              |      |
| ed, Del |                                     |              |      |
| inquent |                                     |              |      |
|  or At- |                                     |              |      |
| Risk of |                                     |              |      |
|  Droppi |                                     |              |      |
| ng-Out  |                                     |              |      |
| Program |                                     |              |      |
+---------+-------------------------------------+--------------+------+
| **Indi  | # Description                       | ### Status   | ##   |
| cator** |                                     |              | Page |
|         |                                     |              |      |
| **N     |                                     |              |      |
| umber** |                                     |              |      |
+---------+-------------------------------------+--------------+------+
| 1.1     | The SEA has implemented all         | Finding      | > 35 |
|         | required components as identified   |              |      |
|         | in its Title I, Part D (N/D) plan.  |              |      |
+---------+-------------------------------------+--------------+------+
| 1.2     | The SEA ensures that State agency   | Met          | NA   |
|         | (SA) plans for services to eligible | requirement  |      |
|         | N/D students meet all requirements. |              |      |
+---------+-------------------------------------+--------------+------+
| 1.3     | The SEA ensures that local          | Met          | NA   |
|         | educational agency (LEA) plans for  | requirement  |      |
|         | services to eligible N/D students   |              |      |
|         | meet all requirements.              |              |      |
+---------+-------------------------------------+--------------+------+
| 2.1     | The SEA ensures that                | Met          | NA   |
|         | institutionwide programs developed  | requirement  |      |
|         | by the SA under Subpart 1 use the   |              |      |
|         | flexibility provided to them by law |              |      |
|         | to improve the academic achievement |              |      |
|         | of all students in the school.      |              |      |
+---------+-------------------------------------+--------------+------+
| 3.1     | The SEA ensures each SA has         | Met          | NA   |
|         | reserved not less than 15 percent   | requirement  |      |
|         | and not more than 30 percent of the |              |      |
|         | amount it receives under Subpart 1  |              |      |
|         | for transition services.            |              |      |
+---------+-------------------------------------+--------------+------+
| 3.2     | The SEA conducts monitoring of its  | Met          | NA   |
|         | subgrantees sufficient to ensure    | requirement  |      |
|         | compliance with Title I, Part D     |              |      |
|         | program requirements.               |              |      |
+---------+-------------------------------------+--------------+------+

# Title I, Part D (Programs for Neglected and Delinquent Youth)

## Accountability

**Indicator 1.1-- The SEA has implemented all required components as
identified in its Title I, Part D plan.**

**[Finding]{.underline}**: The DC SEA did not ensure timely release of
Title I, Part D funds to Oak Hill Academy. Oak Hill Academy reported not
having funding at the start of the school year to effectively implement
its subgrant. Interviews with the staff of Oak Hill Academy and DCPS
indicated that Oak Hill Academy was required to utilize its own funds to
operate its neglected and delinquent youth program while awaiting
Federal funds. Even though Title I funds were available in October 2005,
Oak Hill Academy had received no Title I funding at the time of the
onsite monitoring review. When Oak Hill Academy receives its Title I,
Part D funds, monies will then be reimbursed to its operating budget.

[Citation]{.underline}: 20 USC 6421 section 14101(b) of ESEA states that
ED shall make grants to State educational agencies to enable such
agencies to award subgrants to State agencies and local educational
agencies to establish or improve programs of education for neglected,
delinquent, or at-risk children and youth. Additionally, 20 USC 6422
section 1402 states that ED shall allocate to each State educational
agency an amount necessary to make subgrants to State agencies under
Subpart 1. EDGAR Part 76 Subpart 3, enumerates the SEA's general
administrative responsibilities for subgrants, as well as its fiscal
control and fund accounting procedures. Sec. 76.702 of EDGAR states that
an SEA and a subgrantee shall use fiscal control and fund accounting
procedures that ensure proper disbursement of and accounting for Federal
funds.

[Further action required]{.underline}: ED requires documentation and an
assurance that the Subpart 1 State agency program will be provided with
subgrant funding in a timely manner, and such funding will be available
throughout the school year so that the State agency program has
sufficient funding at the start and end of each grant year.