District of Columbia Opportunity Scholarship Program: Actions Needed to Address Weaknesses in Administration and Oversight
Highlights
What GAO Found
The DC Children and Youth Investment Trust Corporation (the Trust) provides information to prospective and current families of children participating in the District of Columbia (the District) Opportunity Scholarship Program (OSP) through a variety of outreach activities. To reach prospective OSP families, the Trust advertises through print, radio, and bus ads, as well as in newspapers and flyers posted in neighborhood libraries, recreation centers, and local government service centers. However, the Trust provides incomplete and untimely information about participating schools to OSP families. The participating school directory, which is published by the Trust, lacks key information about tuition, fees, and accreditation. The Trust published the directory 9 months after the start of the 2012-13 school year, too late to assist families in selecting a school for that year. Without such information, parents cannot make fully informed school choices. Additionally, the Trust awarded scholarships to students several months after many schools completed their admissions and enrollment processes, limiting the amount of time and choice in selecting schools. Most families GAO spoke with were generally happy with OSP but some were concerned about the availability of program information.
The Trust's internal controls do not ensure effective implementation and oversight of OSP. Adequate policies and procedures can provide reasonable assurance of effective, efficient operations, reliable financial reporting, and compliance with applicable laws. However, the Trust's policies and procedures do not include a process for verifying eligibility information that schools selfreport. As a result, the Trust cannot ensure that schools are eligible to participate in the program and, therefore, risks providing federal dollars to students to attend schools that do not meet standards required by law. Furthermore, the Trust's database is not well structured and hampers the effectiveness of program implementation. For example, the Trust lacks written documentation for the database, and staff must rely on institutional memory to ensure processes such as data entry are conducted properly, which could contribute to errors in the database. As required by law, the Trust groups eligible applicants into three priority categories by which scholarships are then awarded by lottery; however, weaknesses in the database's structure puts into question the Trust's ability to provide accurate priority categories. Additionally, the Trust has not submitted its mandatory financial reports on time, despite a legal requirement that these reports be filed within 9 months of the end of the entity's fiscal year. The Trust's fiscal year 2010 financial report was almost 2 years late, and the Trust's fiscal year 2011 and 2012 reports had not yet been submitted as of August 2013. In August 2013, the Trust also made amendments to its policies and procedures in three areas GAO identified. However, these amendments do not address all weaknesses identified in this report, and have not yet been fully implemented.
The Department of Education (Education) has provided limited assistance to the Trust in certain areas outlined in the memorandum of understanding (MOU) with the District and in the cooperative agreement with the Trust. Specifically, Education is responsible for helping the Trust make improvements to its financial system, enhance its site visit policies and procedures, and improve the accuracy of information provided to parents. Trust officials acknowledged that Education has provided general assistance regarding administrative and operational functions, but it has not assisted with specific improvements in these areas. Although the MOU is a written agreement between Education and the District, it holds the Trust, as the grantee, responsible for notifying District agencies to conduct required building, zoning, health, and safety inspections of participating schools—a requirement that is not detailed in the cooperative agreement signed by Education and the Trust—but would assist the Trust in providing continued oversight of schools participating in OSP. As a result, Trust officials were not acutely aware of this responsibility, and required inspections were not being conducted in the manner described in the MOU between Education and the District.
Why GAO Did This Study
School vouchers, a school choice program designed to provide students with public funds to attend private schools, feature prominently in policy discussions about education reform. The OSP was reauthorized by Congress in 2011 by the Scholarships for Opportunity and Results Act, and has garnered national attention as the first federally-funded voucher program. Since the program's inception in 2004, Congress has provided almost $152 million for the program benefitting almost 5,000 students, currently providing scholarships of about $8,000 for grades K-8 and about $12,000 for grades 9-12. As requested, GAO examined (1) the extent to which the Trust provides information that enables families to make informed school choices, (2) whether the Trust's internal controls ensure accountability for OSP, and (3) how Education and District agencies responsible for overseeing OSP have performed their stated roles and responsibilities.
To conduct this work, GAO visited 10 participating schools; interviewed school officials; conducted discussion groups with 14 parents of scholarship students; analyzed key program documents; reviewed generally accepted guiding documents for internal controls; and interviewed officials at Education, relevant District agencies, and the Trust.
Recommendations
GAO is making 10 recommendations to Education to improve OSP, such as ensuring that the Trust publishes a more complete school directory and updates key aspects of its policies and procedures. Education did not indicate agreement or disagreement with our recommendations. The Trust disagreed with some findings and both provided additional information.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should revise the June 2013 cooperative agreement between Education and the Trust to include Education's expectations for the Trust regarding collaboration with District agencies to ensure they conduct required building, zoning, health, and safety inspections. |
Education provided a copy of the updated cooperative agreement, dated December 2014, between Education and the D.C. Children and Youth Investment Trust Corporation (Trust). The updated cooperative agreement specifies that the Trust will notify the D.C. Department for Consumer and Regulatory Affairs, D.C. Fire and EMS Department, D.C. Department of Health, and D.C. Office of the State Superintendent of Education annually of participating schools, to enable these agencies to confirm each school's compliance with required building and zoning, fire inspection, health and safety and non-public school educational regulations, and to take appropriate follow-up steps.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should work with the Mayor of the District of Columbia to revise the memorandum of understanding that governs OSP implementation to include processes that will help ensure that the results of OSP school inspections, when they are conducted, are communicated to the Trust. |
In September 2017, Education provided documentation of a cooperative agreement between the Department and the program administrator (Serving Our Children) of the DC Opportunity Scholarship Program. The cooperative agreement states that the program administrator would notify the District's Department of Consumer and Regulatory Affairs, Fire and Emergency Management Services, Department of Health, and the Office of the State Superintendent of Education annually of participating schools to enable these agencies to confirm each school's compliance with required regulations. Education also provided examples of the letters that the program administrator sent to these agencies in January 2017. Each letter requested that the District agencies advise the program administrator regarding whether or not participating schools were in compliance with program requirements.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should explore ways to improve Education's monitoring and oversight of the Trust. For example, Education could require the Trust to develop and implement a plan for how it will address its timeliness in mandatory financial reporting. |
In July 2014, Education stated that the Trust was current with all required audits, including 2013. In addition, Education provided its 2014 Grant Award Notification (GAN) for the Trust's operation of OSP, which included a special condition imposed on the Trust due to its history of untimely financial reporting. Specifically, the GAN states that if the Trust fails to submit a timely financial audit or written explanation with documentation establishing that the Trust was not required to undergo a financial audit, drawdown conditions will apply until one of these items is provided. In addition, further award conditions and/or sanctions may apply including, 1) the Trust may be placed on cost-reimbursement; 2) Education may withhold a percentage of federal awards until the financial audit is completed satisfactorily; 3) Education may withhold or disallow overhead costs; 4) Education may suspend federal awards until the financial audit is conducted; or 5) the grant award may be terminated. According to the GAN, timely submission of required financial audits would result in this special condition being removed.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should conduct activities to ensure that the Trust publishes the school Directory prior to participating schools' application deadlines with more complete information. |
According to Education officials, The Trust published the school directory in a timely manner. For the 2014-15 school year, the school directory was published in December 2013. For the 2016-17 school year, the school directory was published in December 2015 under the new OSP administrator, Serving Our Children. The school directory for the 2016-17 school year also includes additional information, such as information on decision notifications, teacher qualifications, parent participation, and report card issuance.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should conduct activities to ensure that the Trust more closely aligns its scholarship timeframes with schools' admissions and enrollment schedules. Education could find ways to assist the Trust in executing the OSP lottery earlier in the school year, for example, by allowing the Trust to use the prior year's income information to make preliminary determinations regarding eligibility. |
In February 2016, Education stated that the Trust did not submit the proposal needed to change its program procedures and process requirements, nor did the Trust indicate plans to submit such a proposal. Education stated that without this proposal, it cannot take any further action. The Trust was replaced by Serving Our Children to administer the DC OSP in August 2015, and as such, is no longer the DC OSP program administrator. In September 2017, Education stated that a lottery was not held because the number of eligible applicants did not exceed funding availability.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should conduct activities to ensure that the Trust improves its OSP database by creating and maintaining documentation for the use of the database, adding automated checks to the system, creating flags and/or variables for the key priority categories called for in the SOAR Act, and streamlining the data entry process for new applications in order to ensure there is sufficiently reliable data regarding the operation of the program. |
In September 2017, Education provided a document describing the current program administrator's technology upgrades and data management. The program administrator, launched a new database - Scholarship Tracking and Application Review System (STARS) - in August 2016 and October 2016. The document describes various ways in which the new database increases efficiency for families, schools, and the administrator. The document also describes the database-related internal controls - such as user authentications and mass data upload capabilities - to ensure that reliable data are available to inform the administration of the program.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should require the Trust to update its policies and procedures in several key respects, and monitor the Trust's activities to ensure that these updates are made. These updates should include identifying the steps the Trust will take to verify reported information on participating schools' compliance with reporting and program requirements specified in the Scholarships for Opportunity and Results Act (SOAR) Act. |
In September 2017, Education provided documentation of the program administrator's policies that requires participating schools to sign a Letter of Agreement, which commits schools to comply with all program requirements. Further, the policy described the program administrator's use of site visits at least once every two years to verify reported information on participating schools' compliance with reporting and program requirements. Education also provided examples of the documentation collected during actual site visits to verify the school's compliance.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should Require the Trust to update its policies and procedures in several key respects, and monitor the Trust's activities to ensure that these updates are made. These updates should include identifying the specific risks that should be included in the evaluation performed when assessing participating schools' financial sustainability information, including a record of the analyses performed, and ensure that the conclusions reached with regard to schools' financial sustainability are documented. |
In September 2017, Education provided documentation of the program administrator's policy informing participating schools of more stringent financial management requirements. Specifically, the program administrator requires an audit of participations schools' finances by a Certified Public Accountant. The audited financial statements and management letter are required to be submitted to the program administrator. This requirement is effective starting any fiscal year after March 2016.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should require the Trust to update its policies and procedures in several key respects, and monitor the Trust's activities to ensure that these updates are made. These updates should include specifying a process for addressing schools that are noncompliant with program requirements. |
In September 2017, Education provided documentation of the program administrator's policy that states that non-compliant participating schools are notified that they may no longer participate in the program, and that participating students attending their school may no longer use program funds to pay for tuition or other expenses.
|
| Department of Education | To ensure families receive expanded opportunities for school choice and OSP is implemented and overseen effectively, the Secretary of Education should require the Trust to update its policies and procedures in several key respects, and monitor the Trust's activities to ensure that these updates are made. These updates should include providing more detailed procedures in key areas including calculating yearly administrative expenses, and performing monthly and year end reconciliations of the OSP bank account, and ensure the document reflects current practices and that key decisions associated with administrative expenses are documented |
In February 2016, Education stated that it had reviewed the Trust's policies and procedures and would provide feedback to the Trust where needed. The Trust's school verification form for SY 2013-14 required schools to self-certify that they met certain requirements stated in the SOAR Act. However, this action does not appear to address this recommendation.
|