District of Columbia Opportunity Scholarship Program: Additional Policies and Procedures Would Improve Internal Controls and Program Operations
GAO-08-9
Published: Nov 01, 2007. Publicly Released: Nov 01, 2007.
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Highlights
The D.C. School Choice Incentive Act created the first private kindergarten-through-grade-12 school-choice program supported by federal funds. The program was named the D.C. Opportunity Scholarship Program (OSP). GAO was asked to assess the (1) accountability mechanisms governing the use of funds, (2) results of the grantee's efforts to meet the program's recruiting priorities and eligibility requirements and inform parents of their choices, and (3) extent that the evaluation of OSP reflects statutory requirements and the implementation of the program supported the detection of useful and generalizable findings. To assess the program, GAO analyzed financial, program, and evaluation data. GAO did not assess the performance of participating private schools nor did GAO evaluate the impact of the program.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Education | Given the importance of using funds appropriately to further program objectives and help ensure that schools are safe and provide sound educational experiences, parents are given accurate information about schools their children may attend, and program oversight is sufficient. The Secretary of Education should direct the Washington Scholarship Fund (WSF), the grantee, to establish and implement detailed policies and procedures to improve financial controls over Opportunity Scholarship Program (OSP) grant funds, including specific requirements for the process of approving scholarship payments and documentation of the process. |
On May 14, 2010, the DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program from the Washington Scholarship Fund. The Trust has developed a policies and procedures manual that fully articulates specific requirements for approving scholarship payments. The Trust also built into their processes segregation of duties so that no on individual decides which scholarship payments to be made. Additionally, the Trust has made a number of improvements to the program's information systems that document payments.
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| Department of Education | Given the importance of using funds appropriately to further program objectives and help ensure that schools are safe and provide sound educational experiences, parents are given accurate information about schools their children may attend, and program oversight is sufficient. The Secretary of Education should direct WSF, the grantee, to establish compensating controls, such as supervisory review, to reduce the risk of fraud in situations where segregation of duties is not possible due to the size limitations of OSP's staff so that no one employee can authorize, process, review, and have access to the funds relating to OSP. |
The DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program from the Washington Scholarship Fund (WSF). Because the Trust has considerably more staff than did WSF, they have been able to build in controls such as the segregation of duties that help reduce the potential risk of fraud. No additional compensating controls are needed.
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| Department of Education | Given the importance of using funds appropriately to further program objectives and help ensure that schools are safe and provide sound educational experiences, parents are given accurate information about schools their children may attend, and program oversight is sufficient. The Secretary of Education should direct WSF, the grantee, to continue its efforts to implement an integrated financial management system to facilitate processing and recording of scholarship payments and overall financial reporting. |
The Washington Scholarship Fund closed its doors. On May 14, 2010, the DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program. As of September 2012, it is too soon to determine whether the Trust has been able to integrate its information system with its financial systems.
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| Department of Education | Given the importance of using funds appropriately to further program objectives and help ensure that schools are safe and provide sound educational experiences, parents are given accurate information about schools their children may attend, and program oversight is sufficient. The Secretary of Education should direct WSF, the grantee, to develop and implement procedures for conducting site visits, including that site visit reports be prepared and contain information on the overall financial stability of the school. |
On May 14, 2010, the DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program. The Trust has developed protocols to guide the site visits it conducts at schools. Each school is visited at least once a year. Those schools with certain risk characteristics may receive multiple visits. The Trust collects financial statements from each school on an annual basis. GAO is in the process of evaluating these financial statements.
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| Department of Education | Given the importance of using funds appropriately to further program objectives and help ensure that schools are safe and provide sound educational experiences, parents are given accurate information about schools their children may attend, and program oversight is sufficient. The Secretary of Education should direct WSF, the grantee, to develop procedures to ensure that accurate information is provided to parents before a school is chosen about the summary achievement data of students, teacher qualifications, and tuition levels, and that schools make such information available on an annual basis to parents of enrolled students. |
The Washington Scholarship Fund closed its doors. On May 14, 2010, the DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program. The Trust requires that each school sign a participating agreement. These agreements require schools to attest to legislatively required information such as summary achievement data for students, teacher qualifications, and tuition levels.
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| Department of Education | The Secretary of Education should collaborate with the Mayor of the District of Columbia to ensure participating schools are in compliance with all relevant District of Columbia education and safety requirements, including school accreditation and health, safety, and fire code requirements, and receive approval to operate in the District. |
On May 14, 2010, the DC Children and Youth Investment Trust Corporation (the Trust) assumed the role of administrator of the Washington Scholarship program from the Washington Scholarship Fund. The Trust developed and approved MOUs that articulate the roles and responsibilities of each entity. This will enhance its ability to ensure schools are in compliance. The Secretary of Education and DCPS should continue to monitor the adequacy of these agreements and future compliance.
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| District of Columbia | The Mayor of the District of Columbia should direct the Office of the State Superintendent of Schools to collaborate with the Board of Education to develop and implement procedures for ensuring that private schools in the District meet applicable District requirements and to actively participate in the oversight of OSP. |
The District agreed with our recommendation and noted that the Mayor delegated direct oversight responsibility under the MOU with Education to the District's State Superintendent of Education. The Superintendent subsequently met with Education to discuss oversight issues identified by GAO, as well as monitoring the Washington Scholarship Fund's (WSF) compliance with statutory and regulatory requirements. Because the original MOU did not specify coordination or division of oversight roles, the Superintendent recommended to Education that they enter into a follow-on agreement to clearly assign roles and responsibilities. The Superintendent also met with WSF to explore ways that the District could help them better comply with federal and local statutes and regulations. The Superintendent assigned a staff member to act as the liaison with Education and WSF to ensure that the District's oversight obligations under the follow-on agreement were met. Finally, the Superintendent's office is developing a way to track the compliance of all non-public schools in the District with local regulations.
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| Department of Education | In planning for future programs for which Congress has required an evaluation, the Secretary of Education should take steps to make certain the program to be evaluated is overseen to ensure it is implemented in a manner consistent with the evaluation design. |
The Department of Education has taken steps toward this end. In May 2012, ED reaffirmed Westat as the contractor for the mandated evaluation. The new contract includes a requirement to submit its design plans for review and comment to the District of Columbia's Public School system. As the contract proceeds, Education should make sure to monitor Westat's plans.
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Topics
AccountabilityAccounting proceduresAccounting standardsAuditsEducation program evaluationEducational grantsEligibility criteriaFederal fundsFinancial managementInternal controlsPrivate schoolsProgram evaluationProgram managementRisk assessmentScholarship programsSchoolsStudent financial aidPolicies and proceduresProgram implementation