United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on the District of Columbia, Committee

on Government Reform and Oversight,

House of Representatives

August 1997 DISTRICT OF COLUMBIA

PUBLIC SCHOOLS

Student Enrollment Count

Remains Vulnerable to

Errors

GAO/HEHS-97-161

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-275273 

August 21, 1997

The Honorable Thomas M. Davis

Chairman, Subcommittee on the District of Columbia

Committee on Government Reform and Oversight

House of Representatives

Dear Mr. Chairman:

The District of Columbia Public Schools (DCPS) is one of the largest public

school districts in the country—ranked 32nd in school year 1993-94,1

 on

the basis of student count, out of nearly 15,000 districts. During school

year 1996-97, DCPS operated 158 elementary and secondary schools and

reported its official student enrollment to be 78,648. DCPS’ budget was

more than $570 million in fiscal year 1997—16 percent, or $90 million, of

which came directly from federal government programs providing grants

and funds.2

As early as school year 1989-90, questions about the accuracy of DCPS’

enrollment count arose when the previous year’s enrollment count was

approximately 6,400 fewer students than had been reported. Even before

school year 1989-90, school system figures were at odds with other

independent counts. In 1984 and again in 1986, the Department of

Education’s Office for Civil Rights released figures differing from DCPS’

official counts by more than 5,000 and 2,000, respectively. More recent

critics have found discrepancies when comparing the reported enrollment

with census estimates and with the District’s general population decline.

In addition, various reviewers and auditors have questioned several

aspects of DCPS’ enrollment count process.

These criticisms raise concern because an accurate enrollment count is

the cornerstone of a school district’s financial needs assessments.

Although in the past DCPS did not receive funds on the basis of the number

of students enrolled, new budget initiatives will soon directly link DCPS’

funding to school enrollment. Consequently, a valid enrollment count

process and an accurate count are critical to DCPS’ district- and schoollevel planning, staffing, funding, and resource allocation.

1

The latest year for which official rankings are available.

2

The annual appropriation act passed by the Congress provided the rest; the act makes funds

(including locally generated revenues and the federal payment) available to the District of Columbia

for obligation and expenditure.

Page 1 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

In response to these issues, you asked us to examine the enrollment count

process that DCPS used in school year 1996-97 to determine whether the

process appeared sufficient to produce an accurate count. In addition, you

asked us to examine enrollment count processes used by some other

urban school systems and to determine the role of the U.S. Department of

Education’s Inspector General in preparing DCPS’ official enrollment count

for school year 1996-97.

To conduct this review, we obtained relevant documents from and we

interviewed DCPS administrative staff, city officials, officials in other urban

school districts3

 and their state departments of education, officials in the

Department of Education, and education experts. To gain an

understanding of the process’ implementation, we visited 15 DCPS

elementary and secondary schools, randomly selected by school level

(elementary, junior high or middle school, and senior high) and city

quadrant (Northeast, Northwest, Southeast, and Southwest).4

 During our

school visits, we interviewed principals, school administrative staff, and

teachers and reviewed selected documents. Further information on our

scope and methodology appears in appendix I.

Results in Brief Even though DCPS changed parts of its enrollment count process in school

year 1996-97 to address criticisms, the process remains flawed. Some of

these changes, such as the use of an enrollment card to verify attendance,

increased complexity and work effort but did little to improve the count’s

credibility. Errors, including multiple enrollment records for a single

student, remained in the Student Information System (SIS), but DCPS had

only limited mechanisms for correcting these errors. For example, though

Management Information Services (MIS) personnel maintain SIS, they have

no authority to correct errors. Furthermore, DCPS’ practice of allowing

principals to enroll unlimited out-of-boundary students increases the

possibility of multiple enrollment records for one student.

Problems also persisted in the critical area of residency verification. In

school year 1996-97, schools did not always verify student residency as

3

The other districts were Boston and Chelsea, Massachusetts; Fairfax County and Arlington County,

Virginia; and Montgomery County and Prince George’s County, Maryland. We interviewed officials and

examined documents they provided, but we did not confirm whether their processes were

implemented as they described.

4

The schools visited were Anacostia High School, Bowen Elementary School, Coolidge High School,

C.W. Harris Elementary School, Deal Junior High School, Eliot Junior High School, Miner Elementary

School, Montgomery Elementary School, Noyes Elementary School, Phelps Career High School,

Randle Highlands Elementary School, Roosevelt High School, Terrell Elementary School, Thomson

Elementary School, and Tubman Elementary School.

Page 2 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

required by DCPS’ own procedures. Proofs of residency, when actually

obtained, often fell short of DCPS’ standards. Moreover, Central Office staff

did not consistently track failures to verify residency. Finally, school staff

and parents rarely suffered sanctions for failure to comply with the

residency verification requirements.

In addition, the pupil accounting system failed to adequately track

students. SIS allowed more than one school to count a single student when

the student transferred from one school to another. In addition, schools

did not always follow attendance rules, and SIS lacked the capability to

track implementation of the rules. Furthermore, some attendance rules, if

implemented, could have allowed counting of nonattending students.

Other school districts report that they use several approaches to control

errors, such as the ones we identified in DCPS, and to improve the accuracy

of their enrollment counts. These include using centralized enrollment and

pupil accounting centers and a variety of automated student information

system edits and procedures designed to prevent or disallow pupil

accounting errors before they occur.

Finally, the recently enacted District of Columbia School Reform Act of

19955

 requires the enrollment count process to produce enrollment

numbers for nonresidents and students with special needs. DCPS (acting on

behalf of the District of Columbia Board of Education) and the District of

Columbia Financial Responsibility and Management Assistance Authority

(Authority) are not in compliance with requirements of this new law,

including a specified annual report on the enrollment count and its

subsequent independent audit. The U.S. Department of Education helped

DCPS develop its Request for Proposals (RFP) for the independent audit of

the enrollment count for school year 1996-97, but it had no role in

preparing DCPS’ official enrollment count for school year 1996-97. The

Authority subsequently decided, however, that auditing the count for

school year 1996-97 would be counterproductive.

Background Unlike other U.S. school districts, DCPS, due to its location in the nation’s

capital, has a unique administrative environment. Because Washington,

D.C., is not located in a state, DCPS does not benefit from the oversight and

assistance often provided by states. Furthermore, recent organizational

changes in both the city and its school system have changed

administration of the schools.

5

Title II of P.L. 104-134 (1996).

Page 3 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

To reform the District’s school system, the Congress recently passed the

District of Columbia School Reform Act of 1995, which includes

requirements for counting District students. Counting student enrollment,

a process involving several interconnected elements, is usually

fundamental to assessing funding needs and required of most other U.S.

school districts. DCPS’ enrollment count process in school year 1996-97 was

centered in the local schools and modified somewhat to address

criticisms.

DCPS’ Administrative

Environment Is Unique

DCPS lacks the state-level oversight that most other school districts in the

country have. The state’s role in school operations is an important one.

States generally provide guidance to their school districts on important

issues, including student enrollment counts. The state determines the rules

to be used in the enrollment count—who should be counted, by what

method, and when. States also distribute state and federal funds to their

districts, usually on the basis of enrollment, and they routinely audit

various school district operations, including the enrollment count.

The governance of DCPS had been performed for many years by an elected

Board of Education. In November 1996, however, the specially appointed

District of Columbia Financial Responsibility and Management Assistance

Authority (Authority) declared a state of emergency in DCPS and

transferred DCPS management—until June 30, 2000—to the Authority’s

agents, a nine-member, specially appointed Emergency Transitional

Education Board of Trustees.6

 In so doing, the Authority transferred to the

Board of Trustees “. . . all authority, powers, functions, duties,

responsibilities . . .” of the former Board of Education7

 (with some

exceptions not relevant to this report). Meanwhile, the Authority also

replaced DCPS’ superintendent with a Chief Executive Officer/

Superintendent. These changes have resulted in a shift of control from

elected officials toward those appointed for a specific purpose: to reform

the system. Early reform initiatives have included the administrative

reorganization of DCPS and the closure of 11 schools.

Even before the Authority’s takeover of DCPS, the Congress, relying on its

plenary power to legislate for the District of Columbia, acted directly to

reform DCPS. In April 1996, the Congress passed the District of Columbia

School Reform Act of 1995, calling for the calculation of the number of

6

The president of the Board of Education is one of nine members of the Board of Trustees.

7

The Board of Education retained an advisory role on general educational policy and remains the

chartering authority for Public Charter Schools under the School Reform Act.

Page 4 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

students enrolled in DCPS. The law requires the District of Columbia Board

of Education8

 to do the following:

• calculate by October 15 of each year the number of students enrolled in

the District’s public schools and students whose tuition in other schools is

paid by DCPS funds, including students with special needs9

 and nonresident

students, in the following categories by grade level if applicable:

kindergarten through grade 12, preschool and prekindergarten, adult

students, and students in nongrade level programs;

• calculate the amount of fees and tuition assessed and collected from

nonresident students in these categories;

• prepare by October 15 and submit to the Authority, the Comptroller

General of the United States, appropriate congressional committees, and

others an annual report summarizing those counts; and

• arrange with the Authority to provide for the conduct of an independent

audit of the count. Within 45 days of the Authority’s receipt of the annual

report—or as soon thereafter as is practicable—the Authority is to submit

the independent audit report to the appropriate congressional committees.

Most School Districts Must

Count Student Enrollment

The requirement to count students is common to most other U.S. school

districts. Forty-one of the 50 states10 use some type of direct student count

to assess resource needs and to distribute state funds to their school

districts. Enrollment counts also usually determine budgets and resource

allocations to the individual schools.

Three basic methods are used for counting enrollment. One method—

called Enrolled Pupils (often called ENR)—counts all enrolled students on

a specified day of the year. Definitions of “enrolled students” vary among

districts, but they usually include elements of attendance. That is, students

must be in attendance at least once during some preceding time period.

ENR is used by 12 states and the District of Columbia. Another similar

method is called Pupils in Average Daily Membership (often called ADM).

This method, used by 22 states, calculates the average of total enrollment

8

The Resolution that established the Board of Trustees specifically transferred all Board of Education

responsibilities regarding the District of Columbia School Reform Act to the newly created Board of

Trustees.

9

The law defines a “student with special needs” as a student who is a child with a disability under the

Individuals With Disabilities Education Act, or a student who is an individual with a disability under

the Rehabilitation Act of 1973 as amended.

10Seven states use teacher or instructional units rather than student count, and two states use other

methods to distribute funds.

Page 5 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

figures over a specified time period.11 A third method, called Pupils in

Average Daily Attendance (often called ADA), calculates the average total

daily attendance over a specified time period. Seven states use this

method.

Enrollment counts may occur several times throughout the school year in

response to both state and local information needs and may use different

counting methods depending on the purpose of the count. For example,

officials in one district reported that they perform a count about 5 days

after school opens, using the ENR method. The district uses this count to

make final adjustments to school-level resource allocations for the current

school year. On September 30, the district conducts the first of three

state-required enrollment counts, also using the ENR method. The state

uses this count to assess compliance with state quality standards (such as

pupil/teacher ratios) and to estimate enrollment before the March 31

count. On March 31, the district conducts the second state-required count,

this time using the ADM method. The state uses this count to distribute

state funds. Finally, the district conducts the third state-required

enrollment count at the end of the school year, also using the ADM method.

The state uses this count as a final report on enrollment for the entire

school year. In addition to fulfilling reporting requirements, the school

district uses the state-required enrollment counts for local planning and

monitoring purposes.

States vary in their approach to monitoring and auditing their districts’

enrollment counts. Some states do little monitoring or auditing of their

districts’ counts, while others stringently monitor and audit. For example,

one state simply reviews district enrollment reports for the fall and spring

and contacts districts if large discrepancies exist. In contrast, another

state not only conducts an electronic audit of its districts’ spring and fall

official enrollment counts, but also visits districts and examines a random

sample of student records in detail. School district officials in this state

reported that the state withdraws from its districts state funds paid for

students improperly enrolled or retained on the rolls.

Regardless of when the count is performed or by what method, whether

audited or not, accuracy is critical. A student count may be inaccurate if it

has problems in any of at least three critical areas: enrollment, residency

verification, and pupil accounting. Enrollment and residency verification

take place when a student enters the school system. They determine a

student’s initial eligibility and therefore who may potentially be included

11Maryland and Massachusetts require ENR; Virginia requires ADM.

Page 6 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

in the count. Pupil accounting refers to the tracking of students after initial

enrollment. Monitoring student attendance, status, and transfers in and out

of school are all part of pupil accounting, which often involves an

automated student database. The pupil accounting system provides the

basis for determining continued eligibility to be counted—based upon a

student’s attendance—and it helps determine which school may count a

particular student in its enrollment.

Accuracy of DCPS’

Enrollment Count Has

Been Questioned

Critics have often charged that the District’s reported official enrollment

numbers have been overstated. One reviewer asserted, for example, that

results of the 1990 U.S. census suggest that the District’s school-age

population in 1990 might have been as much as 13,000 less than DCPS’

official enrollment count. Subsequent reviewers, including a certified

public accounting firm, the Office of the District of Columbia Auditor, and

us, examined the process that DCPS used to count pupils in school years

1994-95 and 1995-96 and found flaws. These flaws included DCPS’ lack of

documentation to support enrollment status and lack of sanctions if false

enrollment information was provided. These reviewers also reported that

DCPS lacked adequate procedures to verify residency and that the student

database had errors, including duplicate records, incomplete transfers,

and incorrect enrollment status. For a more detailed discussion of audit

findings and recommendations, see appendix II.

DCPS’ Enrollment Count

Process in School Year

1996-97 Remained

Centered in the Local

Schools

DCPS’ process for enrolling, verifying residency of, and tracking students

remained centered in the local school in school year 1996-97, while central

office staff monitored portions of the process. To respond to past

criticisms, DCPS instituted some changes for school year 1996-97, including

new forms, residency verification procedures, and additional preparatory

counts. The actual official enrollment count was done manually, and

school principals were ultimately responsible for ensuring the accuracy of

their schools’ counts.

Local Schools Conducted

Enrollment Activities

DCPS’ local schools conducted all enrollment activities in school year

1996-97 for new and returning students, and the schools’ principals made

all determinations about enrollment eligibility. Principals were allowed to

enroll students who lived outside school boundaries without limitation.

Principals could also temporarily enroll students who had not provided

evidence of meeting eligibility criteria, including health certificates and

proofs of District of Columbia residency. Upon completion of initial

paperwork, the schools’ data entry clerks created an electronic record for

Page 7 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

each newly enrolled—or temporarily enrolled—student in SIS.

12 The

system maintained records for returning students from the previous

school year, and the records were updated during the summer with

promotion information. Similarly, withdrawals were processed during the

summer, and these records were removed from the schools’ rolls. Figure 1

shows the enrollment count process for school year 1996-97.

12SIS has been used for the past 3 years, replacing the former Student Information Membership System

(SIMS). It contains biographical, demographic, academic, and status information on each student

enrolled in DCPS.

Page 8 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

Page 9 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

Figure 1: DCPS Enrollment Count Process for School Year 1996-97

Returning 

Student 

Records 

Updated as 

of September

2

Homeroom

Rosters

Prepared

SIS Shows

All Students

as "Active"

SIS

File

Updated

to Show

New

Enrollees

SIS

File

Updated

to Convert

"No-Shows"

to "Inactive"

SIS

File

Updated

With

Addresses

SIS

Rosters

Generated

for

Preliminary

Count

Responsibility

Individual

School

Summer

1996

Enrollment

Cards

Completed

Student Residency

Forms Completed

and Submitted

With Proofs

Attendance Rosters

Reviewed for

"No-Shows"

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

School Provides Daily Membership Counts

to Central Office

Central

Office

Initial Monitoring

September

Transfers/New Students

3 19

Page 10 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

September

20 21 22 23 24 25 26 27 28 29 30 1 2 4 5 8 9 10 12

October December

Transfers/New Students

Preliminary

Count Performed

Using SIS

Rosters

SIS

File

Reconciled

With

Enrollment

Cards and

Updated

Official Count

Forwarded

Residency Forms

Forwarded

Preliminary Counts

Forwarded

Central

Office

Released

Count

Central

Office

Reconciled

and

Aggregated

Numbers

Residency Validation Visits

New Procedures in School Year 1996-97

Interim Enrollment Monitoring Final Enrollment Monitoring

3 11

Sept. 3 - First Day of School

Sept. 19 - Preliminary Count

Oct. 3 - First Official Count

Dec. 11 - Official Count Released

Official

Count 

Performed

SIS

Rosters

Generated

for

Official

Count

The process in school year 1996-97 incorporated the use of a new

enrollment card designed to address auditors’ concerns about validating

enrollment status. Students were to complete two copies of the enrollment

Page 11 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

card on the first day of attendance, and teachers were to sign and certify

the cards. A completed card was to serve as proof that a child had

appeared the single day required to be considered enrolled. In addition to

serving as proof of enrollment status, the card was to be used to update

SIS.

Process Required Evidence of

Residency

In addition to the enrollment card, DCPS’ enrollment process for 1996-97

required all students to provide evidence of District of Columbia

residency. If the student provided no evidence, DCPS’ rules allowed the

student to enroll, but the student was to be assessed tuition. Tuition for a

full-time program for school year 1996-97 ranged from $3,349 to $7,558,

depending on grade level.

Providing evidence of District of Columbia residency was required as part

of revised DCPS procedures for school year 1996-97 to answer critics who

charged that DCPS’ process for verifying residency was inadequate. In

previous years, only students entering DCPS schools for the first time would

have been required to submit proof of residency. A new form, the Student

Residency and Data Verification Form, which had been piloted at selected

schools during the previous school year, was to be completed for all

students during school year 1996-97. Students were expected to have their

parents or guardians complete the form and return it to the school with

proofs of residency attached. Schools were to give students 3 days to

complete and submit the form and proofs. Within 10 days, the school was

to provide one copy of the form to the Nonresident Tuition Enforcement

Branch of the Central Office along with a list of those students for whom

residency had not been verified. The Nonresident Tuition Enforcement

Branch was responsible for assessing and collecting tuition.

Pupil Accounting Also Resided

in the Local Schools

In addition to enrollment and residency verification procedures, local

schools also tracked student attendance, status, and transfers in school

year 1996-97. Each of DCPS’ schools had online access to school data, and

the schools’ data entry personnel (or enrollment clerks) were responsible

for ensuring data were accurate and up to date. The MIS Branch, however,

in the Central Office, managed the overall database.

Classroom or homeroom teachers took attendance once a day, and data

entry staff recorded it in SIS. Transfers were often done electronically, with

transfer procedures initiated by the losing school and completed by the

gaining school, although a manual back-up transfer process was also

available.

Page 12 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

Monitoring Activities Included

Use of Enrollment Cards and

Identifying Nonresidents

Monitoring activities for school year 1996-97 focused exclusively on

overseeing the schools’ implementation of the enrollment card and on

identifying nonresidents. During the early part of the school year, DCPS’

Central Office staff visited each of the schools three times to monitor

enrollment cards. Eighteen members of the Central Office staff were

temporarily reassigned to monitor the cards. Staff paid the first monitoring

visit within the first 2 weeks of school and focused on the extent to which

schools were following the process, that is, distributing and completing

enrollment cards and filing them in the appropriate locations. Staff paid

the interim monitoring visit before the official enrollment count and

manually tallied students, comparing the enrollment cards, SIS reports, and

the preliminary count documents. Staff paid the final monitoring visit after

the October 3 count and were to verify that names on the enrollment cards

matched those on SIS homeroom rosters.

Nonresident students of the District of Columbia were to be identified

through local schools’ monitoring of the completed data verification

forms. The Nonresident Tuition Enforcement Branch was to investigate

cases the schools identified. In addition, staff from this branch were to

visit the schools to survey cars transporting students to and from school,

identifying all out-of-state license plates. The monitors were also to review

enrollment cards and residency verification forms to determine if the

forms indicated residency issues. The branch was to investigate all

identified cases and assess tuition for students found not meeting the

District’s residency requirements.

DCPS Used ENR to Count

Students

As previously mentioned, for school year 1996-97, DCPS used the ENR

method to count its students—counting all enrolled students on a single

day—October 3, 1996. Students did not have to attend school on this day

to be included in the count because enrollment records were counted—

not actual students. DCPS defined an “enrolled student” as any student who

had appeared at school at least once—and who had not withdrawn from

DCPS—between the beginning of the school year on September 3, 1996, and

October 3, 1996, the day of the count.

DCPS’ October 3, 1996, count was conducted manually by each homeroom

teacher using homeroom rosters prepared from SIS. School staff compiled

the count, classroom by classroom, and recorded the numbers on the

school’s official report. The Central Office received the schools’ reports,

and schools’ data were aggregated by the Office of Educational

Page 13 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

Accountability (OEA),13 which prepared the official enrollment report.14

Each school’s principal was to ensure not only the accuracy of the

school’s manual count, but also the enrollment, residency, and pupil

accounting data that supported it. DCPS’ policy for the October 3, 1996,

count called for unspecified rewards and sanctions to be applied on the

basis of the extent to which staff maintained and reported accurate,

up-to-date information.

Beyond the official October count, DCPS also performed other counts

throughout the year using this same process. These included official

counts in December and again in February. The February count aided in

computing projections for school year 1997-98. In addition to these counts,

DCPS began two new preparatory counts this year. Each school took daily

enrollment counts and communicated them by telephone to the Central

Office every morning for the first 11 days of the school year. In addition, in

September, each school completed a preliminary count using forms

established for the official October 3 count.

School Year 1996-97

Enrollment Process

Changes Did Not

Ensure Accuracy

DCPS’ new student enrollment card was intended to document that

students had met the 1-day attendance requirement for inclusion in the

official enrollment count. Although the card may have met this

requirement in some respects, it appears to have burdened both school

and DCPS staff and may not offer much advantage over more traditional

methods of documenting attendance, such as teachers’ attendance

tracking. Perhaps even more importantly, the card alone did not ensure

that enrollment records were correct before the count. The card did not

address a critical problem—one revealed by prior audits—a lack of

internal controls of the student database. This problem allowed multiple

records to be created for a single student. Furthermore, DCPS continued to

include in its enrollment some categories of students often excluded in

official enrollment counts used for funding purposes in other states. In

contrast to DCPS procedures, officials in other school districts reported

using various strategies for ensuring accuracy and minimizing duplicate

records.

13OEA was dissolved in winter 1997 by the DCPS’ new Chief Executive Officer/Superintendent as part

of his administrative reorganization. Many of OEA’s functions were transferred to the office of the

Chief Academic Officer.

14District of Columbia Public Schools, FY 1996-97 Official Membership, October 3, 1996, DCPS

(Washington, D.C.: Dec. 1996).

Page 14 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

Enrollment Card Appears

to Be Burdensome and

Inefficient

Teachers and school staff reported that DCPS’ new enrollment card was

burdensome and difficult to implement. Each child, on the first day of

attendance, had to complete and sign two separate copies15 of the card.

However, many students—primarily the very young, disabled, or nonEnglish speaking—could not complete the card themselves because they

could not read or write at all or do so in English. In these cases, teachers

had to complete the enrollment cards, although the students were asked to

sign the cards when possible. Teachers, particularly in the primary grades,

reported that completing the cards was troublesome for them, adding to

their paperwork burden. Furthermore, the legitimacy of a child’s signature

as a method of validation—particularly when the child cannot read or

write—is questionable.16

In addition, the enrollment card did not contain vital enrollment

information needed by the schools, such as emergency contact numbers.

Consequently, it could not substitute for other enrollment forms that

schools had been using. Several of the schools we visited augmented the

enrollment card with other forms to obtain needed information.

Consequently, the busy school staff had to complete and manage multiple

forms to collect and maintain basic enrollment data.

Moreover, the procedures that DCPS established for completing the

enrollment card were difficult to implement after the first days of the

school year. The procedures, which required the teacher to certify the

student’s signature, were designed for the initial few days of school when

an entire class enrolled together and could complete the form in the

teacher’s presence. No provision had been established for students

arriving later, who normally enroll at the school office. School staff in the

schools we visited reported that they could not sign the card for the

teacher, and obtaining the teacher’s signature and certification for these

late enrollments was sometimes difficult. As a result, the process

sometimes failed when enrollment cards for late enrollees were not

completed or signed and certified by teachers.

Finally, DCPS officials reported that Central Office monitoring for

implementation of the new enrollment card was labor intensive.

Enrollment card monitoring efforts did not use statistical sampling.

Instead, we were told, monitors visited all the schools on three separate

15One of the cards was to stay with the teacher, and one was forwarded to the school’s office to be

maintained in files by classroom.

16The six districts we visited have similar attendance requirements but do not require this type of

validation, depending instead upon attendance data to prove that the student was present.

Page 15 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

occasions, often reviewing 100 percent of the enrollment records. To

perform this task, monitoring teams were formed, without regard to their

normal responsibilities, from available staff within the former OEA,

according to DCPS officials. During our review, we could not confirm the

extent of these enrollment card monitoring visits because DCPS could not

provide us with any of the monitoring reports prepared on the basis of

these visits.

Lack of Internal Controls

Allowed Multiple

Enrollment Records

The procedures that DCPS used for enrolling students in school year

1996-97 allowed multiple records to be entered into SIS for a single student.

When school staff entered a new record, the SIS processing procedure

automatically queried the database for any matching names and dates of

birth. If a match occurred—as would be the case if the student had

previously enrolled in a DCPS school—SIS informed the person entering the

data that a record already existed for an individual with that name and

date of birth. SIS, however, also provided the option of overriding the

system and creating a new record for the student. DCPS officials reported

that some data entry personnel were choosing this override capability and

creating the new record. With safeguards overridden and additional

records created, two schools could have each had access to a separate

record for the same individual, allowing both schools to count the student.

DCPS’ mechanisms for resolving this error were limited. Although Central

Office MIS personnel maintained SIS, they had no authority to correct the

errors once detected. Only the local school had such authority. MIS

personnel had limited influence over the schools to ensure that

corrections were made quickly and accurately, according to DCPS officials.

Furthermore, while duplicate record checks were done, officials told us,

the checks were not done on a regular, routine schedule. In addition,

individuals who had helped with data quality control in the past as well as

those who had monitored attendance were moved in early 1997 to

facilities without office telephones or data lines.17

DCPS’ practice of allowing schools to enroll, without restriction, students

who live outside school attendance boundaries increased the possibility of

a student’s having multiple enrollment records for school year 1996-97.

Students did not have to enroll in the school serving the geographic area

where they lived but could enroll in any DCPS school if the principal

allowed. For example, a student could have gone first to the school

17DCPS officials told us that they had no plans to relocate the personnel or install telephone lines

before the collocation of DCPS offices in the spring of 1998. Staff members, instead, will continue to

be expected to travel to a local school when they need to perform SIS data runs.

Page 16 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

serving his or her area, filled out an enrollment card, and been entered into

SIS. Subsequently, the student may have gone to another school, filled out

another enrollment card, and—if the person entering this record in SIS

chose to override the safeguard—been entered into SIS a second time. In

addition, some principals reported that schools actively sought to attract

out-of-boundary students to increase their enrollment.

Enrollment Procedures

Allow Count of Students

Not Counted in Some

Other Districts

DCPS’ official enrollment count of 78,648 included not only regular

elementary and secondary students, but also other categories of students

excluded from enrollment counts in other districts when the counts are

used for funding purposes. For example, DCPS included in its enrollment

count students identified as tuition-paying nonresidents of the District of

Columbia and students above and below the mandatory age for public

education in the District, including Head Start participants,18

prekindergarten students (age 4), preschool students (age 0 to 3), and

some senior high and special education students aged 20 and older.19 In

contrast, the three states we visited reported that they exclude any student

who is above or below mandatory school age or who is fully funded from

other sources from enrollment counts used for funding purposes.

Furthermore, even though the District of Columbia Auditor has suggested

that students unable to document their residency be excluded from the

official enrollment count, whether they pay tuition or not, DCPS included

these students in its enrollment count for school year 1996-97.

Other Districts Report

Using Various Methods to

Help Improve Enrollment

Accuracy

In contrast with the DCPS process, students in the Boston and Chelsea,

Massachusetts, school districts enroll at central Parent Information

Centers (PIC), which are separate and independent from the schools,

officials told us. Individual schools in these two districts cannot enroll

new students, we were told. All enrollment activities, including assignment

of all students to schools, take place at PICs. Boston’s PICs were established

as a key part of the U.S. District Court’s desegregation plan to alleviate the

Court’s concerns about the accuracy of Boston’s reported enrollment

numbers and to satisfy the Court’s requirements for credibility and

accountability in pupil enrollment, assignment, and accounting.

Centralizing student enrollment at PICs has helped reduce errors,

according to officials in both districts. For example, staff in Boston have

18Head Start has its own funding source.

19The Reform Act requires separate reporting of some of these groups but does not require that they be

included in aggregate counts.

Page 17 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

specialized in and become knowledgeable about the process. Limiting

access to the student database has also helped to reduce errors. For

example, in Boston, only six people may enter data into the database.

Furthermore, PICs prevent students from being enrolled at two or more

schools simultaneously, reducing duplicate counting and preventing

schools from inflating their enrollment.

In the other four districts we visited, schools—rather than a central

site—usually handle student enrollment,20 but they use other safeguards.

To enroll, a student goes to the school serving the geographic area in

which he or she lives. Out-of-boundary enrollment is not usually allowed.21

In addition, officials in all four of these districts reported having student

database safeguards to aid enrollment accuracy. For example, all four

districts have procedures and edits in their student databases that

automatically block the creation of duplicate enrollment records. If an

enrolling student has attended another school in the district, these

procedures will not allow a new record to be created once the old record

has been located. School staff, officials told us, cannot override this

blocking mechanism. In addition, Prince George’s County has a procedure

in its student database that automatically checks student addresses with

school attendance boundaries as enrollment information is entered. If the

address falls outside the enrolling school’s boundaries, the database

blocks enrollment.

New Residency

Verification

Procedures Were Not

Completely

Implemented

During school year 1996-97, District of Columbia schools had features that

attracted nonresidents. Elementary schools in the District had free all-day

prekindergarten and kindergarten, and some elementary schools had

before- and after-school programs at low cost. One school we visited had

before- and after-school care for $25 per week. This program extended the

school day’s hours to accommodate working parents—the program began

at 7 a.m. and ended at 6 p.m. In addition, several high schools had highly

regarded academic and artistic programs; and some high schools had

athletic programs that reportedly attracted scouts from highly rated

colleges. Furthermore, students could participate in competitive athletic

20Officials in the Fairfax County school district said that new students with limited-English proficiency

and new students with disabilities enroll and verify residency at central service centers designed to

help students with special needs.

21Arlington County school district officials told us that after enrolling, their students are allowed to

seek transfers to out-of-boundary schools for academic reasons. Schools may accept such transfers as

long as they do not exceed 4 percent of their total enrollment. Fairfax County and Prince George’s

County also allow attendance at out-of-boundary schools under special circumstances, with

permission of the central administration.

Page 18 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

programs until age 19 in the District, compared with age 18 in some nearby

jurisdictions.

DCPS established new procedures for school year 1996-97 to detect

nonresidents and collect tuition from those who attended DCPS schools,

but both school and Central Office staff failed to implement the new

procedures completely.22 In addition, DCPS failed to monitor and enforce its

new procedures effectively.

Schools Failed to Verify

and Report Residency for

All Students as Required

by DCPS Policy

Most of the schools we visited failed to comply with the new residency

verification process. As discussed previously, all students’ parents or legal

guardians had to complete a Student Residency and Data Verification

Form (residency form) and provide at least two proofs of residency.

Students were told that failure to provide either the completed residency

form or proofs would result in an investigation of their residency, and, if

appropriate, either tuition payments or exclusion from DCPS. Most of the

schools we visited, however, did not obtain completed residency forms for

all their students. In fact, only 2 of the 15 schools had—or reported

having—residency forms for 100 percent of the student files we reviewed.

In addition, schools did not collect all required proofs of residency.

Students and their families presented two proofs of residency in only

isolated cases, and many students submitted no proofs. In many other

cases, the proofs that the schools collected did not meet the standards

established by DCPS and printed on the residency form. Although the

residency form specified proofs of residency, such as copies of deeds,

rental leases, utility bills, or vehicle registrations, as acceptable, schools

sometimes accepted proofs such as newspaper or magazine subscriptions,

copies of envelopes mailed to the student’s family, stubs from paid utility

bills with no name attached, and informal personal notes (rather than

leases or rental agreements) from individuals from whom the family

reportedly rented housing. We also found some instances in which the

names or addresses on the proof did not match those on the form. School

staff often complained to us about the difficulty they had trying to get

students to return completed residency forms and proofs. Some

acknowledged that they placed little emphasis on this effort.

Schools we visited also varied in their compliance with the requirements

to report residency issues to OEA. Schools were supposed to forward

copies of all students’ completed residency forms to OEA. These copies

22Audit reports of the Oct. 1995 count also criticized DCPS for failure to verify student residency.

Page 19 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

were to be attached to a list of students whose residency was considered

questionable. Some schools sent copies of their student residency forms

along with the list as required. Others sent the proofs with the forms. At

least six schools sent no verifications of residency to the Central Office.

Some of these implementation issues may have resulted from poorly

specified requirements and procedures. For example, though DCPS officials

reported to us that the requirements were for at least two proofs of

residency, we found no written documentation communicating to the

school staff or to the students a requirement for more than one proof. DCPS

officials also gave us conflicting information about the number of proofs

required. At one meeting, we were told that three proofs were required; at

a later meeting, that two to three were required.

Similarly, DCPS’ guidance to the schools did not specify how the schools

were to maintain their students’ completed residency documentation—or

even exactly what documentation was to be maintained. Consequently,

schools’ maintenance of residency documents varied considerably. For

example, about one-third of the schools we visited maintained the

residency forms alphabetically; the remaining schools grouped them by

classroom. The schools’ disposition of the proofs of residency varied even

more. Eight schools filed proofs of residency with the students’ completed

residency forms; one filed the proofs in the students’ permanent

(cumulative) record folder; one filed them either with the completed form

or in the folder; one placed all proofs in a file drawer without annotating

them to permit subsequent identification of the student to whom they

belonged; two forwarded all proofs to OEA, along with copies of the

completed form; and two schools had no proofs at all for the student

records we reviewed. And, because procedures did not provide for the

schools to document the proofs on the residency forms, schools not

retaining the proofs with the forms could not demonstrate that they had

adequately verified residency. Other audits of schools’ compliance with

residency verification would face similar obstacles because of the schools’

inability to link student records with proof of residency.

Central Office Did Not

Effectively Monitor or

Enforce Residency

Verification Procedures

Monitors for student residency, in general, did not report the level of

school and student noncompliance that we observed in our review. For

the nine schools for which we could directly assess compliance,23 with few

exceptions, proofs of residency were missing for large portions of the

23We could assess compliance only for those schools for which we could track the proof of residency

to the residency form.

Page 20 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

student population. But, most DCPS Daily Activity Reports (monitoring

reports) failed to cite the missing proofs, focusing instead on students who

lived with someone other than a parent or whose forms indicated a

nonresident address or phone number. For example, in one school we

visited, we determined that about one-fourth of the students (or 108) did

not return a proof to the school. The DCPS monitoring report, however,

identified only one student living with a grandmother and two students

with nonresident addresses. In another school, we found no proofs, and

staff reported that they could not get students to provide proofs. But the

monitoring report showed that only two students had nonresident

addresses or phone numbers. Moreover, DCPS officials did not provide

monitoring reports for 3 of the 15 schools we visited, telling us that it only

prepared monitoring reports for schools where issues of nonresidency had

been identified on enrollment cards or residency verification forms. At one

of the three schools without monitoring reports, we found no proofs of

residency on file for any student.

Some of the monitors’ failure to detect and report residency problems may

have resulted from poorly specified guidance. Instructions to monitors

were not specific enough to guide implementation, for example, asking

monitors to identify students for whom parents had not “sufficiently

documented” residence. Monitoring instructions did not specify what to

examine to determine whether residency was documented or what

documentation was considered sufficient.

Furthermore, despite recommendations of previous audits, monitors had

no instructions to review the files to determine whether students had

submitted a residency form. Consequently, when monitors failed to

compare names on the student roster with those on completed residency

forms, DCPS missed a key element in determining school and student

compliance. We found forms missing for at least some of the students at 13

of the 15 schools we visited. At one school, the staff estimated that about

25 to 30 percent of the students did not return the residency forms, and, at

another school, the staff could not find about one-third of the forms.

Despite monitoring efforts and threats of sanctions, DCPS administration

did not ensure that the schools completed the residency verification

procedures. DCPS conducted no follow-up of schools failing to submit the

office copy of the residency form. In addition, on the basis of the reports

from the schools we visited, it conducted only minimal follow-up of

schools failing to collect adequate proofs. Furthermore, as noted earlier,

DCPS conducted no follow-up of those schools failing to collect residency

Page 21 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

forms for all students because no one in the Central Office checked to see

if all forms had been received.

In addition, the Central Office did not consistently apply the established

sanctions to the students or their families for failing to submit forms or

proofs. As noted earlier, parents and guardians were told that failure to

provide proof could result in an investigation, a tuition bill, or exclusion

from DCPS. On the basis of our visits to 15 schools, we assessed the degree

of student noncompliance as very high. In one school alone, staff

estimated that about 80 percent of the students—or about 700 students—

did not comply. Yet, for all 158 schools, the Nonresident Tuition

Enforcement Branch reported that, as of May 1, 1997, it issued only 469

letters to students requesting them to submit proofs of residency,

collected tuition from only 35, and excluded only 156 students from DCPS

schools. Action was pending for another 136. DCPS officials in the

Nonresident Tuition Enforcement Branch told us that, at the request of

one of the assistant superintendents, they were focusing their enforcement

action mainly on high school athletes largely because the athletic program

may have been attracting nonresidents.

Other Districts Also Verify

Residency

Like DCPS, all the other districts reported that all new students must verify

residency upon enrolling. Residency verification occurs either at the

individual schools or at central service centers. Officials in Boston and

Chelsea reported that the PICs verify residency. Officials in the other four

districts told us that all or most new students enroll and verify residency at

the school they will attend. School staff verify residency and check to see

that the student’s address falls within the attendance boundary of the

school. If the parent fails to provide satisfactory proof of residency, the

child is not allowed to enroll.

Other districts reported relying upon the schools to verify residency for

continuing students. For example, officials in Arlington, Fairfax, and

Prince George’s counties told us that teachers and principals are expected

to monitor continually for students’ possible relocation, and students must

provide information on address changes. Schools also often make use of

returned mail as a reliable data source for address changes. None of the

other districts we visited requires annual residency verification for all

students as DCPS does.

Page 22 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

System for Pupil

Accounting Did Not

Ensure an Accurate

Count

The foundation of the pupil accounting system—SIS—lacked adequate

safeguards to ensure that students were accurately tracked when they

transferred from one school to another. Furthermore, some schools did

not follow attendance rules, affecting later counts and projections. These

rules, if implemented, may have allowed some students who no longer

attended to be included in the school’s count.

SIS Process for

Transferring Students

Allowed More Than One

School to Include a

Student in Its Active

Enrollment

The student transfer process may have allowed a single student to be

enrolled in at least two schools simultaneously.24 During most of the

school year, a student’s record could be accessed and modified only by the

school in which the student was enrolled. When a student transferred,

however, the losing school was to submit the student’s record to a

computer procedure that allowed both the losing and gaining school to

have identical copies of the student’s record. During this process, both

schools could enter the student’s status as “active” or “inactive.” The

computer procedure provided no safeguards to ensure that the student

was only active at one school at a time. Until the losing school completed

the computer procedure with a withdrawal code, both schools could have

claimed the student as active or enrolled. The possible impact of this

vulnerability upon the count may have been sizeable. DCPS officials

reported that the number of transfers between schools in the District

during school year 1996-97 was well in excess of 20,000.

DCPS officials in the MIS Branch, concerned with this problem, performed

periodic data runs to detect cases in which students were shown as

enrolled in two schools. Resolving these issues and completing the

transfers, however, sometimes involved a lengthy delay. We found cases

that took as long as 1 to 2 months to resolve. Local schools made all

changes—the MIS Branch did not have authority to change the data—and

some school staff did not use the electronic transfer procedures.

Furthermore, DCPS did not specify a time limit for completing the transfer.

In addition, students could also be counted at more than one school when

the massive transfers took place at year end during “roll-over”—when

students transferred as a group to either middle or high school. During

school year 1996-97, well over 6,800 roll-overs took place, and the process

was multistaged and generally occurred when students were still enrolled

in the elementary or middle schools, officials said. SIS has a programming

24This problem is separate from the multiple record issue discussed earlier, in which two separate SIS

records, with different student identification numbers, were created for a single individual. In the

transfer process, only one record exists (in two copies)—and one identification number per student,

and the two copies of the record can be accessed by both schools.

Page 23 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

anomaly allowing students to have active status in both schools’

databases, according to DCPS officials.

Sometimes students were legitimately enrolled in two schools

simultaneously, for example, when attending a regular high school

program in addition to one of the School-to-Aid-Youth (STAY)25 programs.

In these cases, the database of the school with the secondary program—

STAY—should have shown the student with the special status of “enrolled”

and the student’s regular school should have shown his or her status as

“active.” The student should have only been counted at the school where

active. School clerks did not use the “enrolled” code properly, however,

and, because the status code had no safeguards, the student could be

counted at both schools, according to DCPS officials.

Limitations in Capability to

Track Attendance Could

Have Affected Accuracy of

Student Database

During school year 1996-97, two attendance rules directly affected student

status and therefore the number of students eligible to be counted.

First, schools were to reclassify as inactive, or in this case as a “no-show,”

any student expected to enroll but not actually attending school at least

once during the first 10 days of school. Students classified as inactive

would not be included in the official enrollment count. No-shows,

however, were sometimes not reclassified as inactive as required by the

attendance rules. While most schools we visited appeared to be following

this rule, at least one school we visited apparently had difficulty changing

these students’ status to inactive. At this school, the data entry staff

reported that they were having trouble maintaining student status as

“inactive” for the no-shows. Some of these students were appearing on

their active rolls as late as February, possibly affecting DCPS’ official count.

Second, schools were required to change to inactive status those students

who showed up for at least 1 day but subsequently accumulated 45

consecutive days of absences. For students who had 45 days of absences,

schools reported that they only rarely changed their status to inactive.

School officials often told us that they did not change a student’s status

unless they could obtain accurate information about the student’s

whereabouts, confirming that the student should be dropped from the

rolls. School administrators stated reluctance to “give up on a student,”

and they viewed changing the student’s status to inactive as such. Unlike

the no-show rule, failing to implement the 45-day rule would not have

25High school students are sometimes sent to a STAY program when they need to make up academic

deficiencies. In these cases, the STAY program focuses on the deficiencies, while the student

maintains enrollment for the remaining courses at his or her regular high school.

Page 24 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

directly affected the October count. It would have affected, however,

subsequent counts and the accuracy of projections from them.

The 45-day attendance rule, if implemented, may have allowed some

nonattending students to be considered active and enrolled. The rule

enabled any student who reported 1 day to be considered enrolled until

evidence was obtained that he or she had transferred elsewhere or until 45

days had elapsed. If a student went to another school district without

notifying the school, the school would not have known to drop the student

from its rolls. Consequently, even if the student appeared only on the first

day of school, the 45-day time period would not have expired before the

official enrollment count, allowing a student to be counted who no longer

attended a DCPS school.

This 45-day time period might be considered lengthy by some other nearby

districts. Other school districts we visited reported that they have shorter

time periods. For example, Virginia law requires that students with 15 or

more consecutive days of absence be withdrawn from school, district

officials told us. Therefore, neither Arlington County nor Fairfax County

counts any student with 15 or more days of consecutive absence. Neither

does Boston count any student in this category.

SIS provided no safeguards to ensure that the schools followed either the

no-show rule or the 45-day rule. It had no feature that would allow

students’ status to be automatically changed to inactive on the basis of

absences. Nor could SIS identify students with 45 consecutive days of

absence—it does not readily permit calculating consecutive days of

absence for students throughout the school year. Consequently, quality

control or management assistance from the MIS Branch on this issue was

not possible.

Other Districts Rely on

Centralized Processing or

Automated Database

Procedures to Control

Possible Errors in Pupil

Accounting

Other districts we visited reported using essentially the same approaches

for controlling errors in tracking student transfers as they use for

controlling enrollment and residency verification. For example, in Boston,

all student transfers take place through the PICs, where a limited number

of staff may process the transfers. The schools lack the authority or ability

to transfer students.

In most of the other districts, officials reported that the individual schools

handle student transfers. These districts rely on a variety of automatic

edits and procedures in their student database systems to prevent such

Page 25 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

errors and serve as ongoing checks and balances on the schools. For

example, in Arlington, Fairfax, Prince George’s, and Montgomery counties,

the student database systems either do not allow a transfer to proceed

unless the losing school removes the student from its rolls or

automatically removes the student from the losing school as part of the

transfer process. The school cannot override these safeguards.

In addition, Arlington, Fairfax, and Prince George’s counties reported

using two centralized oversight mechanisms for further enhancing

accuracy in accounting for student transfers. First, they regularly and

frequently check their student databases for duplicate student entries

using students’ names and dates of birth as well as identification numbers.

These checks also help to safeguard against multiple student entries

arising from other sources such as enrollments. Arlington County

performs this check every 15 days; Fairfax County, every 2 weeks; and

Prince George’s County, daily concerning transfers.

Second, if these districts identify duplicates, they notify the school

immediately and work with the school to resolve the situation, officials

reported. For example, Prince George’s County reports duplicates from

transfers to the schools every day; when school staff log onto the

computer system in the morning, the first thing that appears is an error

screen showing duplicates from transfers as well as any other errors.

Prince George’s County officials also review these schools’ error screens

and follow up daily. If schools do not respond, according to these officials,

database management staff can readily access senior district officials to

quickly resolve such problems. In addition, in Arlington, Fairfax, and

Prince George’s counties, Boston, and Chelsea, the database staff may

make changes to the student database.

As in DCPS, all six of the districts we visited reported to us that teachers are

responsible for tracking daily attendance and schools for recording

attendance data in the student database. Most of the other districts

reported that they also use their central student databases to track all

student absences as a check on the schools’ tracking. In addition, several

districts withdraw students from school after substantially fewer days of

consecutive absences than DCPS. For example, in Boston and Arlington and

Fairfax counties, students absent 15 days in a row are withdrawn from

school. They are therefore not included in school or district enrollment

counts. These students must re-enroll if they return.

Page 26 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

DCPS, the Board of

Trustees, and the

Authority Have Not

Complied With the

District of Columbia

School Reform Act

The District of Columbia School Reform Act of 1995 imposed enrollment

count reporting and audit requirements upon DCPS, the District of

Columbia Board of Education—all of the responsibilities of which have

been delegated to the Board of Trustees—and the Authority. The Reform

Act requires the District’s schools to report certain kinds of information.

The schools did not collect all the information required to be reported, and

the official enrollment count that was released did not comply with the

Reform Act’s requirements. In addition, the Reform Act requirements to

independently audit the count have not been met.

The Reform Act requires an enrollment count that includes—in addition to

data historically reported by DCPS—a report of special needs and

nonresident students by grade level and tuition assessed and collected.

The official enrollment count report released for school year 1996-97—the

first year of the new reporting requirements—failed to provide information

on special needs and nonresident students as well as on tuition assessed

and collected. DCPS has not provided any evidence that additional

documentation was released that would include the required information.

Despite October 1996 correspondence from the U.S. Department of

Education referring them to the law, DCPS officials repeatedly expressed to

us unfamiliarity with the law or the type of information it requires.

The Reform Act also stipulates that the Authority, after receiving the

annual report, is to provide for the conduct of an independent audit. The

Authority, however, had delegated this function to DCPS earlier this year,

according to DCPS procurement officials. With that understanding, DCPS’

Procurement Office, with technical assistance provided by the U.S.

Department of Education Inspector General’s Office,26 issued a Request

for Proposals (RFP). DCPS received proposals in response, and, in early

June 1997, the Procurement Office was preparing to make an award. When

we queried Authority officials at that time about their role in this effort,

however, they reported that they did not know of any DCPS efforts to

procure the audit and were preparing to advertise an RFP for the audit.

Subsequent correspondence from the Authority indicated that the

inadequacies that led to the restructuring of the public school system

would make auditing the count counterproductive. In addition, the

Authority’s comments in response to our draft report reiterated its notion

26In response to DCPS’ request for assistance, the U.S. Department of Education Inspector General’s

Office reviewed DCPS’ draft RFP for an independent audit of the count. The Inspector General’s Office

made recommendations for improvements to the RFP, and DCPS incorporated all of them in the RFP

that it issued. In addition, the Department has offered to review audit plans once a contract award has

been made and make suggestions for revision if necessary. The U.S. Department of Education played

no other role in DCPS’ enrollment count process in school year 1996-97.

Page 27 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

that auditing the flawed count would be counterproductive. In short, the

Reform Act’s requirements to count and report student enrollment and

audit that enrollment count have not been met.

Conclusions Although DCPS has tried to respond to criticisms raised by previous audits,

its efforts have overlooked larger systemic issues. Consequently,

fundamental weaknesses remain in the enrollment count process that

make it vulnerable to inaccuracy and weaken its credibility. For example,

the lack of internal controls allows multiple records and other errors that

raise questions about the accuracy of the database used as a key part of

the count. Furthermore, unidentified nonresident students may be

included in the count when they avoid detection because DCPS’ sanctions

are not enforced.

An accurate and credible enrollment count demands a process with

stringent accountability and strong internal controls. Moreover, the need

to correct DCPS’ problems is more critical now than ever before. Current

reform initiatives have heightened public awareness of the issues and

increased scrutiny of the process. Meanwhile, new budget initiatives for

per pupil accounting will increase this level of scrutiny. Even without the

new initiatives, an accurate enrollment count is essential if DCPS is to

spend its educational dollars wisely.

Matter for

Congressional

Consideration

Because the enrollment count will become the basis for funding DCPS, the

Congress may wish to direct DCPS to report separately, in its annual

reporting of the enrollment count, those students

• fully funded from other sources, such as Head Start participants or

tuition-paying nonresidents;

• above and below the mandatory age for compulsory public education,

such as prekindergarten or those aged 20 and above; and

• for whom District residency cannot be confirmed.

Recommendations We recommend that the DCPS Chief Executive Officer/Superintendent do

the following:

• Clarify, document, and enforce the responsibilities and sanctions for

employees in all three areas of the enrollment count process—enrollment,

residency verification, and pupil accounting.

Page 28 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

• Clarify, document, and enforce the residency verification requirements for

students and their parents.

• Institute internal controls in the student information database, including

database management practices and automatic procedures and edits to

control database errors.

• Comply with the reporting requirements of the District of Columbia

School Reform Act of 1995.

We also recommend that the District of Columbia Financial Responsibility

and Management Assistance Authority comply with the auditing

requirements of the District of Columbia School Reform Act of 1995.

Agency Comments DCPS’ Chief Executive Officer/Superintendent stated that DCPS concurs with

the major findings and recommendations of the audit and will correct the

identified weaknesses. He also acknowledged that the enrollment numbers

for school year 1996-97 are subject to question for the reasons we cited—

especially because the enrollment count credibility hinges almost entirely

on the written verification provided by local administrators. No substantial

checks and balances, no aggressive central monitoring, and few routine

reports were in place. In addition, virtually no administrative sanctions

were applied, indicating that the submitted reports were hardly reviewed.

DCPS’ comments appear in appendix III.

The Authority shared DCPS’ view that many findings and recommendations

in this report will help to correct what it characterized as a flawed student

enrollment process. Its comments did, however, express concerns about

certain aspects of our report. More specifically, the Authority was

concerned that our review did not discuss the effects of the Authority’s

overhaul of DCPS in November 1996. It also commented that our report did

not note that the flawed student count was one of the issues prompting the

Authority to change the governance structure and management of DCPS as

noted in its report, Children in Crisis: A Failure of the D.C. Public Schools.

Although we did not review the Authority’s overhaul of DCPS or the events

and concerns leading to that overhaul, we have revised the report to

clarify the Authority’s transfer of powers and responsibilities from the

District of Columbia Board of Education to the Emergency Board of

Trustees.

The Authority was also concerned about the clarity of our discussion of

the District of Columbia School Reform Act, suggesting that we enhance

this discussion to include the portion of the Reform Act that addresses the

Page 29 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

funding of the audit. We have clarified in the report that the relevant

responsibilities of the Board of Education—including that of funding the

audit—were transferred to the Emergency Board of Trustees.

Finally, the Authority questioned statements made in our report about its

role in preparing an RFP for an audit. Specifically, it disputes our statement

that the Authority was “. . . unaware of any of DCPS’ efforts to produce the

audit and were preparing to advertise an RFP for the audit.” In disputing

our statement, the Authority asserts that this is a misrepresentation of a

conversation between a new employee of the Authority who would have

known nothing about the Authority’s contracting process and our staff. We

disagree that this misrepresents our conversations with Authority staff. In

preparing to meet with the Authority the first time, we spoke with a more

senior, long-time member of the Authority’s staff about the audit issues

who referred us to the new staff member as the expert on District

education issues. When we met with the new staff member, she stated that

she had reviewed the act and had spoken with other staff who were

preparing to develop an RFP. Furthermore, after meeting with this new

staff member, we met a second time with other Authority staff present. At

both meetings, Authority staff expressed unfamiliarity with DCPS’ efforts to

produce an audit. The Authority’s comments appear in appendix IV.

The U.S. Department of Education, in commenting on our draft report,

noted that its Office of Inspector General had no role in preparing DCPS’

enrollment count for school year 1996-97 but provided some clarifications

about correspondence between it and DCPS regarding an audit of the count.

We have revised the report where appropriate. Education’s comments

appear in appendix V.

We are sending copies of this report to the U.S. Department of Education;

the Office of the Chief Executive Officer/Superintendent, District of

Columbia Public Schools; the District of Columbia Financial

Responsibility and Management Assistance Authority; appropriate

Page 30 GAO/HEHS-97-161 DCPS Enrollment Count
B-275273 

congressional committees; and other interested parties. Please call

Carlotta Joyner, Director, Education and Employment Issues, at

(202) 512-7014 if you or your staff have any questions about this report.

Major contributors to this report are listed in appendix VI.

Sincerely yours,

Richard L. Hembra

Assistant Comptroller General

Page 31 GAO/HEHS-97-161 DCPS Enrollment Count
Contents

Letter 1

Appendix I 

Scope and

Methodology

34

DCPS School Sample 34

Other Urban School Districts 35

Appendix II 

Prior Criticisms and

Audits

36

Appendix III 

Comments From

District of Columbia

Public Schools

41

Appendix IV 

Comments From the

District of Columbia

Financial

Responsibility and

Management

Assistance Authority

42

Appendix V 

Comments From the

U.S. Department of

Education

44

Page 32 GAO/HEHS-97-161 DCPS Enrollment Count
Contents

Appendix VI 

GAO Contacts and

Staff

Acknowledgments

46

GAO Contacts 46

Staff Acknowledgments 46

Tables Table I.1: Distribution of Schools in the Population 34

Table I.2: Distribution of Schools in the Sample Selected for Site

Visits

35

Table I.3: Other School Districts Visited 35

Table II.1: Summary of Audits and Observations Conducted of

School Year 1994-95 and 1995-96 Official Enrollment Counts

36

Figure Figure 1: DCPS Enrollment Count Process for School Year

1996-97

10

Abbreviations

ADM Average Daily Membership

DCPS District of Columbia Public Schools

ENR Enrolled Pupils

MIS Management Information Services

OEA Office of Educational Accountability

PIC Parent Information Center

RFP request for proposal

SIMS Student Information Membership System

SIS Student Information System

STAY School-to-Aid-Youth

Page 33 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix I 

Scope and Methodology

We designed our study to gather information about DCPS’ enrollment count

process for school year 1996-97 and the process used by other selected

urban school districts. To do so, we visited DCPS administrative offices,

interviewed administration officials, and reviewed documents. We also

visited randomly selected DCPS schools unannounced, interviewing school

faculty and staff and reviewing student records. In addition, we

interviewed officials in other urban school districts, officials in the U.S.

Department of Education and the District of Columbia, and other experts

in the field. We did our work between October 1996 and June 1997 in

accordance with generally accepted government auditing standards.

DCPS School Sample We visited 15 randomly sampled DCPS elementary and secondary schools

to review documents and interview faculty and staff about DCPS’

enrollment count process. We selected these schools from a list of 158

elementary and secondary schools provided to us by school district

officials. We focused our review on regular elementary and secondary

schools and excluded the two School-to-Aid-Youth (STAY) programs, two

educational centers, and one elementary art center. Therefore, our final

population included 153 schools. Fifteen schools were randomly selected

by city quadrant (Northeast, Northwest, Southeast, and Southwest) and by

level of school (elementary, middle/junior high, and senior high). Table I.1

shows the population distribution, and table I.2 shows the sample

distribution for schools visited.

Table I.1: Distribution of Schools in the Population

Total

City quadrant

Elementary

schools

Middle/junior

high schools

Senior high

schools Number Percent

Northeast 33 8 6 47 31

Northwest 42 9 10 61 40

Southeast 32 6 2 40 26

Southwest 4 1 0 5 3

Total

Number 111 24 18 153 100

Percent 73 16 12 100

Note: Percentages may not add to 100 percent due to rounding.

Page 34 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix I 

Scope and Methodology

Table I.2: Distribution of Schools in the Sample Selected for Site Visits

Total

City quadrant

Elementary

schools

Middle/junior

high schools

Senior high

schools Number Percent

Northeast 2 1 1 4 27

Northwest 3 1 2 6 40

Southeast 3 0 1 4 27

Southwest 1 0 0 1 7

Total

Number 9 2 4 15 100

Percent 60 13 27 100

Note: Percentages may not add to 100 percent due to rounding.

Other Urban School

Districts

We also interviewed officials in other selected urban school districts to

gather general information about their enrollment count processes. Table

I.3 shows the districts we visited with their enrollment count, counting

method, and number of schools for school year 1996-97. We did not visit

schools or interview school faculty or staff in these other districts.

Table I.3: Other School Districts Visited

School district

Enrollment

count for

school year

1996-97

Number of

district

schools during

school year

1996-97

Method used to count

students

Montgomery County Public Schools, Rockville, Maryland 122,505 181 Enrolled Pupils

Prince George’s County Public Schools, Upper Marlboro,

Maryland

122,831 177 Enrolled Pupils

Boston School District, Boston, Massachusetts 63,738 125 Enrolled Pupils

Chelsea Public Schools, Chelsea, Massachusetts 5,302 4 Enrolled Pupils

Arlington County Public Schools, Arlington, Virginia 17,895 30 Average Daily Membership

Fairfax County Public Schools, Fairfax, Virginia 144,599 232 Average Daily Membership

Page 35 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II 

Prior Criticisms and Audits

Critics have charged that DCPS’ reported enrollment numbers are

overstated. Questions raised about the credibility of DCPS’ enrollment

count have led to a series of reviews and audits. This appendix discusses

in detail these efforts, which varied in scope and involved the efforts of

several organizations. Table II.1 summarizes these efforts.

Table II.1: Summary of Audits and Observations Conducted of School Year 1994-95 and 1995-96 Official Enrollment Counts

Issue

Audit/observation

of count, school

year 1994-95

Audits of count,

school

year 1995-96

Enrollment issues

No documentation to support enrollment status X X

No penalty for providing false enrollment information X

Lack of oversight or controls to ensure information in count was accurate X

Nonresidency issues

Poor procedures to validate residency X

Procedures to validate residency not always followed X

Weak controls to detect and follow-up on nonresidency X X

Monitoring efforts failed to reconcile residency forms with rosters Not applicable X

Pupil accounting issues

Enrollment status incorrect X

Transfers not completed X

Duplicate records X X

Questions of system security and reliability X X

Database not routinely updated to reflect current enrollment status X X

No guidance for withdrawing students and excluding them from the count X

Other Issue

Too much time elapsed between count and audit X X

Grier Partnership Criticism

of DCPS’ 1990 Enrollment

Count

In 1995, the Grier Partnership, as part of a study commissioned by DCPS,

asserted that results of the 1990 U.S. census suggested that the District’s

total school-age population in 1990 might have been as much as 13,000 less

than DCPS reported in its official enrollment count. Grier also expressed

concern about the apparent relative stability of DCPS’ official enrollment

count in the face of the District’s declining resident population.

Limitations to the methodology the Grier Partnership used, however, may

have caused the apparent differences to be overstated. For example, Grier

did not include some subgroups—preschool (Head Start),

Page 36 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II 

Prior Criticisms and Audits

prekindergarten, and kindergarten students—that DCPS routinely includes

in its official count. Even if these groups had been included in the

estimates, using census data to estimate public school enrollment can be

problematic. For example, the Census Bureau reports that estimates

generated from its official files undercount some groups. From the 1990

census, the largest group undercounted was “renters.” Census estimates of

pre-primary students enrolled in school are also understated because

parents reporting the number of students enrolled in “regular school”

often fail to include their pre-primary children. Finally, declines in

residency do not necessarily mean declines in school enrollment. Census

currently projects a loss of 31,000 in the District’s population over the next

5 years, while projecting an increase in the number of school-aged

children.

GAO Criticisms of DCPS’

October 1994 Count

The first of several independent audits took place following the September

29, 1994, enrollment count. At that time, DCPS organized an internal audit

and validation of the count. DCPS randomly selected a sample of students

and focused on validating these students’ actual attendance in schools

before the enrollment count. We were asked to observe DCPS’ internal audit

effort.27

We questioned the reliability of the student database, finding that the

database used to enroll and track students—the Student Information

Membership System (SIMS)—included students who had not enrolled

before the official enrollment count. We also found that transfer students

were never removed from SIMS when they transferred. In addition, SIMS had

other errors, was not regularly updated, and had at least 340 duplicate

student records.

We also criticized DCPS’ inability to identify nonresident students and the

absence of procedures to validate residency. DCPS estimated that at that

time approximately 2 percent of its students were probably undetected

nonresidents. DCPS also estimated that this equaled more than $6 million in

lost tuition revenues.

We consequently recommended that DCPS periodically check SIMS for

duplicates and errors, particularly before the official enrollment count,

and update it regularly to reflect the changes in the enrollment status of

DCPS students. We also recommended that DCPS develop systematic

27See District of Columbia: Weaknesses in Personnel Records and Public Schools’ Management

Information and Controls (GAO/T-AIMD-95-170, June 14, 1995).

Page 37 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II 

Prior Criticisms and Audits

procedures at the school level to verify student residency and that schools

refer names of nonresident students to DCPS administration for

enforcement and collection of nonresident tuition.

Independent Auditor’s

Findings Regarding

October 1995 Count

The DCPS Superintendent, after the October 1995 enrollment count,

contracted for an independent audit and validation of the count.28 In

addition to a 100-percent validation of the count, DCPS expected that the

independent auditor would assess the accuracy of DCPS’ Student

Information System29 (SIS) and determine if school and headquarters staff

had followed DCPS’ policies and procedures. The independent auditor

chosen by DCPS conducted a full validation of the enrollment count and

examined SIS for duplicates and errors. The auditor failed, however, to

determine if DCPS school and headquarters staff consistently implemented

the policies and procedures developed by the DCPS administration.30

The independent auditor found several weaknesses in the October 1995

count, including problems with the way the enrollment count was taken

and documented by DCPS staff; lack of residency documentation and

validation; the questionable accuracy of SIS; and the lack of guidance for

withdrawing students and excluding them from the schools’ rolls. For

example, a new form, the Student Residency and Data Verification Form,

used to document residency, was piloted in some schools during school

year 1995-96.31 The auditor found that these forms were sent home to

parents but were not always returned to the schools, and the forms were

not reconciled to student enrollment reports to determine the number of

missing forms. The auditor also found 550 sets of students with the same

name and date of birth, that is, duplicate entries in SIS.

In addition, the auditor criticized the time lapse—about 4 months—from

the October 5, 1995, enrollment count to the audit. This meant that the

auditor could not validate the enrollment of some students—students who

were no longer in school at the time of the audit and for whom the school

28Audit of the Official Membership of the District of Columbia Public Schools as of October 5, 1995,

F.S. Taylor & Associates, P.C. (Washington, D.C.: Apr. 26, 1996).

29SIS replaced SIMS as DCPS’ automated student information database.

30The Office of the District of Columbia Auditor, in its own review and report of the October 1995

enrollment count, criticized the independent auditor’s failure to evaluate the compliance of DCPS’

regulations and guidelines because it was an agreed-upon deliverable in the independent auditor’s

contract with DCPS.

31The Student Residency and Data Verification Form piloted during the 1995-96 school year is the same

form used in school year 1996-97 to verify residency for all students.

Page 38 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II 

Prior Criticisms and Audits

could provide no documentation demonstrating attendance before the

count.

To remedy the problem with duplicate database entries, the auditor

recommended that DCPS periodically search the database for duplicates

and errors before the enrollment count. Because of differences found in SIS

and the manually prepared enrollment count report, the auditor also

recommended that these two data sources be reconciled periodically to

help update SIS.

Regarding timing of the audit, the auditor recommended that the audit of

the official enrollment count take place closer to the date of the count.

And, to facilitate future audits, the auditor suggested that documentation

exist to support a student’s attendance in school before the enrollment

count. The independent auditor also suggested that after an enrollment

count is taken, the staff responsible for monitoring attendance problems

have the opportunity to review the enrollment count so they can remove

from the count those students who have not attended at least 1 day of

school or who have withdrawn from DCPS.

Office of the District of

Columbia Auditor Findings

Regarding the

October 1995 Count

The District of Columbia Auditor, in its audit of the October 5, 1995,

enrollment count,32 found that DCPS needed significantly improved

procedures for student enrollment counts to ensure more reliable and

valid counts. The Auditor’s office expressed concerns about the security

and reliability of SIS, the absence of any penalty for providing false

enrollment information, and the lack of oversight or controls to ensure the

accuracy of the information reported on the enrollment count. In addition,

the Auditor found that SIS was not updated regularly to reflect changes in

the enrollment status of students, particularly before the official

enrollment count.

The Auditor also discussed the weak controls in place to detect

nonresidency and the weak procedures to collect nonresident tuition. The

Auditor found that DCPS did not maintain records on the number of Student

Residence and Data Verification Forms completed and returned by

students’ parents, and it did not test the information on these forms or the

documents provided to support the forms. As a result, the Auditor

reported that according to the DCPS Nonresident Tuition Enforcement

32Review of the District of Columbia Public Schools’ Official Membership Count Procedures, Office of

the District of Columbia Auditor (Washington, D.C.: July 19, 1996).

Page 39 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix II 

Prior Criticisms and Audits

Branch estimates, about 4,000 to 6,000 DCPS students were nonresidents

but did not pay nonresident tuition.

Consequently, the Auditor recommended that each local school

periodically reconcile SIS-generated reports with the attendance records it

maintains. This would allow for adjustments to SIS to include those

students who have physically presented themselves in class and removing

those who have not presented themselves, withdrawn, or transferred.

In addition, the Auditor suggested that unless students could document

their residency, including proof of residency, they should be excluded

from the official enrollment count. Furthermore, the Auditor suggested

that those nonresidents who pay tuition be excluded from the enrollment

count.

Page 40 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix III 

Comments From District of Columbia Public

Schools

Page 41 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix IV 

Comments From the District of Columbia

Financial Responsibility and Management

Assistance Authority

Page 42 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix IV 

Comments From the District of Columbia

Financial Responsibility and Management

Assistance Authority

Page 43 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix V 

Comments From the U.S. Department of

Education

Page 44 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix V 

Comments From the U.S. Department of

Education

Page 45 GAO/HEHS-97-161 DCPS Enrollment Count
Appendix VI 

GAO Contacts and Staff Acknowledgments

GAO Contacts D. Catherine Baltzell, Assistant Director, (202) 512-8001

Dianne Murphy Blank, Evaluator-in-Charge, (202) 512-5654

Staff

Acknowledgments

In addition to those named above, the following individuals made

important contributions to this report: Christine McGagh led numerous

site visits, reviewed DCPS’ enrollment count process, and cowrote portions

of this report; James W. Hansbury, Jr., performed numerous site visits,

reviewed prior audit reports, and summarized those audits. Wayne Dow,

Edward Tuchman, and Deborah Edwards assisted with the visits to the

schools; Sylvia Shanks and Robert Crystal provided legal assistance; and

Liz Williams and Ann McDermott assisted with report preparation.

(104870) Page 46 GAO/HEHS-97-161 DCPS Enrollment Count
Ordering Information

The first copy of each GAO report and testimony is free.

Additional copies are $2 each. Orders should be sent to the

following address, accompanied by a check or money order

made out to the Superintendent of Documents, when

necessary. VISA and MasterCard credit cards are accepted, also.

Orders for 100 or more copies to be mailed to a single address

are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 6015

Gaithersburg, MD 20884-6015

or visit:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders may also be placed by calling (202) 512-6000 

or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and

testimony. To receive facsimile copies of the daily list or any

list from the past 30 days, please call (202) 512-6000 using a

touchtone phone. A recorded menu will provide information on

how to obtain these lists.

For information on how to access GAO reports on the INTERNET,

send an e-mail message with "info" in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov

PRINTED ON RECYCLED PAPER
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. G100