Contract Compliance Audit of. WHLS of Florida, Inc., for Fiscal Year January 19, 2007
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1 Contract Compliance Audit of WHLS of Florida, Inc., for Fiscal Year 2006 January 19, 2007 Report
2 Contract Compliance Audit of WHLS of Florida, Inc., for Fiscal Year 2006 Table of Contents PURPOSE AND AUTHORITY 1 Page SCOPE AND METHODOLOGY 1 BACKGROUND 2 CONCLUSIONS 2 1. Contractual Objectives 2 2. Contract Monitoring Documentation Lacking 4 3. Missing Teaching Certificate 6 APPENDIX Management s Response 7 i
3 THE SCHOOL DISTRICT OF LUNG CHIU, CPA ARTHUR C. JOHNSON, Ph.D. PALM BEACH COUNTY, FLORIDA DISTRICT AUDITOR SUPERINTENDENT OFFICE OF THE DISTRICT AUDITOR 3346 FOREST HILL BLVD., B-302 WEST PALM BEACH, FL (561) FAX: (561) M E M O R A N D U M TO: FROM: Honorable Chair and Members of the School Board Arthur C. Johnson, Superintendent of Schools Chair and Members of the Audit Committee Lung Chiu, CPA, District Auditor DATE: January 19, 2007 SUBJECT: Contract Compliance Audit of WHLS of Florida, Inc., for Fiscal Year 2006 PURPOSE AND AUTHORITY Pursuant to the District s Audit Plan of , we have audited the Contract Compliance of WHLS of Florida, Inc., for Fiscal Year The primary objectives of the audit were to: Determine if the contract s objectives were met; and Assess the adequacy of the District s procedures in monitoring contract compliance. SCOPE AND METHODOLOGY The Contract Compliance Audit of WHLS of Florida, Inc., for Fiscal Year 2006 was performed in accordance with Government Auditing Standards, by Susan Miller during June 14, through July 18, This audit included: Reviewing applicable Florida Statutes, Department of Education (DOE) Rules, and School Board Policies. Reviewing the executed contract between The School Board of Palm Beach County and WHLS of Florida, Inc. dated July 1, Interviewing staff of the Alternative Education Department, and WHLS of Florida, Inc. Reviewing files, documents, and records of selected schools and students to determine the extent of compliance with contract requirements. Our conclusions were brought to the attention of staff during the audit so that necessary corrective actions could be implemented immediately. The draft report was sent to the department for review and comments. Management responses are included in the Appendix. We appreciate the courtesy and cooperation extended to us by staff during the review. The final draft report was presented to the Audit Committee at its January 19, 2007, meeting. 1
4 BACKGROUND The School District entered into a contract with WHLS of Florida, Inc. (WHLS), a corporation based in Akron, Ohio on May 11, 2005, to provide three alternative education school centers for high school age students utilizing the company s Life Skills Center Educational Model. This educational model is an electronic-based/teacher supported framework allowing students to learn at their development level and allowing them to proceed at their own pace. The contract with WHLS was from July 1, 2005 to June 30, As stipulated in the contract, WHLS agreed to operate three school centers serving at least 900 at-risk students at a minimum cost of $5,100,000 and maximum cost of $6,120,000. The cost was based on Full-Time Equivalent student counts during October and February. As of August 28, 2006, the School District paid WHLS $5,294,505 for providing services to 916 students in the WHLS programs during Fiscal Year CONCLUSIONS 1. Contractual Objectives Pursuant to Section 5 of the contract, WHLS was to achieve five objectives by June However, two of the three contractual objectives were not achieved as shown in the table below. Objective Outcome 1. The percent of WHLS students making learning gains in reading and math will be significantly higher than the learning gains of students at other District alternative education sites, as reported in the FY06 School Accountability Report. % Making WHLS School Centers Learning Gains Reading Math WHLS Life Skills West WHLS Life Skills North 9 28 WHLS Life Skills South 8 38 District Alternative Schools Gold Coast School Lake Shore Annex Result: WHLS Did not achieve objective. 2
5 2. 100% of WHLS students will earn a minimum of four (4) credits in FY % of WHLS students earned four or more credits. Result: WHLS did not achieve objective. 3. The percent of students with excessive absences (more than 21 days) will be 15% or less. 15% of WHLS students had excessive absences. Result: WHLS achieved objective. 4. The dropout rate of WHLS students will no higher than 10%. The drop-out rate of WHLS students was 6.47% Result: WHLS achieved objective % of 12 th grade students will be employed or in voluntary service. 100% of WHLS seniors were employed or in voluntary service. Result: WHLS achieved objective. Management s Response: Objective 1: Concur. Students made gains, but not greater than the matched group. The WHLS program students, who are in high school, were compared to middle school students in alternative programs with a different delivery system and program emphasis. Corrective Action: Students progress will be monitored more frequently by WHLS staff and use more aggressively the student progress log. Staff will use the diagnostic reports to monitor progress and drive instruction. Time Line: Immediate and continuing throughout the year. Follow-up: Alternative Education staff will monitor by reviewing random student progress log, diagnostic reports, and computer based assessments used by WHLS. 3
6 Objective 2: Concur. Many students were placed at the WHLS without their input or agreement to the placement by the home schools. Therefore, many of them were not appropriate for the program model and did not succeed despite staffs efforts. Corrective Action: WHLS will actively attend the staffings of future students to make certain the students and their families understand the program and the student s learning style matches the program s delivery method. Administration runs daily, weekly, and monthly reports of credits earned and discusses the progress with staff at regular meetings. Time Line: WHLS will attend staffings immediately. Staff will monitor credits earned quarterly. Follow-up: Alternative Education staff will receive numbers at monthly meetings starting in January 2007, and work on strategies to improve the results if needed. Objective 3: Concur. Objective 4: Concur. Objective 5: Concur. 2. Contract Monitoring Documentation Lacking The Alternative Education Department was responsible for ongoing monitoring of the WHLS contract. Department personnel completed packets demonstrating eligibility for the program and file the packets with the student s cumulative records. Monitoring effort of student progress consisted primarily of observation without formal documentation. The District s Life Skills Center Manager randomly selected student progress records, both hard-copy files and web-based database records, and reviewed them for academic progress and for completeness. However, no record of the monitoring effort, such as which students and what benchmarks, was made. Staff should have developed monitoring documentation that would allow trends, deficiencies, remedial actions, and other proactive plans to be acted on in a timely manner. In addition to documentation of student progress, compliance documentation was needed in the following specific areas. 4
7 Curriculum alignment with Florida Sunshine State Standards. Pursuant to Section 6.f. of the contract, WHLS was to demonstrate their educational model aligned with Florida Sunshine State Standards, which was the basis for all statewide assessment required by the Department of Education. The Alternative Education Department, however, did not maintain documentation demonstrating alignment of instructional software used by WHLS with the Florida Sunshine State Standards. WHLS currently uses the instructional software programs Plato, Fast Forward, and A+. Teacher in-service training. Pursuant to Section 6.j. of the contract, WHLS was to provide inservice training for teachers of best teaching strategies and practices for at-risk youth. There was no proof that the contractor provided such training. WHLS teachers often attended District provided in-service courses. A reciprocal agreement with the contractor might be appropriate to provide District personnel additional training opportunities. Management s Response: Despite having an informal monitoring plan in place, no formal record was kept of monitoring efforts. To correct this, a monitoring form was designed to encompass all deliverable services and was implemented in September There are items that need to be monitored only once a year and some need to be monitored more frequently. The monitoring document has been developed as a continuous monitoring system. Curriculum Alignment: Concur. Corrective Action: After Alternative Education staff spoke with the regional manager of WHLS, the curriculum alignment was overnighted to the Alternative Education Office and it is on file with the contract monitoring documentation. Time Line: Completed July Follow-up: If the curriculum is changed or modified, new documentation of curriculum alignment with Sunshine State Standards will be obtained and kept on file. Teacher In-Service Training: Concur. Corrective Action: Obtain calendar of in-service training. Time Line: Collect in-service information monthly. Follow-up: Alternative Education Staff will collect the information on a monthly basis and file with the contract monitoring materials. 5
8 3. Missing Teaching Certificate The District s Certification Office verifies teaching certification before the contractor can hire a teacher. Copies of each teacher s certificate or eligibility letter are maintained at the Alternative Education Department. Of the five teachers reviewed, one certificate was missing from the Department s files. Staff should periodically review all teaching certificates to ensure qualified instructional personnel is hired. Management s Response: We concur. Corrective Action: Having documentation of teacher certification is part of the monitoring tool. Certification of new teachers is requested upon hire. Time Line: Copies of certificates will be obtained immediately and kept current. Follow-up: The certificates will be monitored on a monthly basis and reviewed at the monthly meeting. End of Report 6
9 Appendix Management s Response from Department of Alternative Education 7
10 Appendix Management s Response from Department of Alternative Education 8
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