A recent Legislative Post Audit (LPA) audit of the Kansas State Department of Education’s funding of the adult virtual school program found KSDE doesn’t comply with its own audit practices and lacks written policies for some important best practices.
KSDE’s response? To question why the audit was conducted in the first place, attack the auditors, and insist the audit should be disregarded.
Some Kansas school districts offer virtual diploma completion programs to adult students 20 and older, and the state provides funding to schools for those students.
The Kansas Division of Legislative Post Audit reviewed approximately 5,900 adult virtual school credits that nine districts submitted in either the 2021-22 or 2022-23 school years. LPA said they chose them because they are the two most recent years that KSDE has audited. The auditors chose five districts in each year, and one district was included in both years. Auditors also reviewed the process and results of KSDE’s audit of those adult virtual school credits for those same years.
“Nearly all the credits the nine districts submitted complied with statutory criteria, but there were a few exceptions,” the report reads. “For the years we reviewed, the nine districts had policies to verify age, but some lacked policies to verify residency. Some districts did not receive funding for credits students earned due to the statutory limit on the number of credits that can be funded each year.”
Auditors also found that KSDE’s audit process does not adequately ensure that the department funds credits that comply with statute, and the process is not consistently applied across districts:
- KSDE audits the credits that districts submit for adult virtual school funding each year.
- For half of the districts we reviewed, KSDE did not approve the number of adult virtual credits that were statutorily compliant. KSDE lacked adequate written policies and procedures to help auditors review adult virtual school credits consistently.
- The department does not consistently follow some of its written policies.
- The department lacks written policies for some important audit best practices.
There also appeared to be issues with one district in particular, USD 112 Central Plains, sharing several concerns:
- The Central Plains school district raised concerns with the results of KSDE’s audit of the adult virtual credits they submitted for the 2021-22 school year.
- We noted a couple of problems with how Central Plains creates and monitors transcripts that contributed to some of the issues with the district’s audit.
- In the 2021-22 school year, KSDE’s approach for reviewing Central Plains’ transcripts resulted in some credits that appeared statutorily compliant not being paid.
LPA recommended Central Plans review all transcripts each year with Graduation Alliance to ensure accurate transcripts.
Auditors additionally recommended:
- KSDE officials create a written policy and procedure manual incorporating the rules the department intends to apply when reviewing adult virtual education credits. The department should ensure those policies do not inadvertently restrict or limit statutorily compliant credits from being funded.
- Incorporate general audit practices such as supervisory review and appropriate audit documentation into their written policies for adult virtual school funding audits, and:
- Once the department has created a written policy and procedure manual for adult virtual school funding audits, officials should train all audit staff to ensure that department policies are consistently followed.
KSDE’s response was to “vehemently disagree” with LPA’s findings, claiming that they had the policy and procedures in place already and that LPA “ has chosen to ignore the KSDE Enrollment Handbook and the state funding rules within it when answering the audit questions approved by the Legislative LPA Committee. This has resulted in LPA not answering the question approved by the Legislative LPA Committee. The second reason for disagreement is that LPA did not follow accepted government auditing standards for conducting the audit and in reaching its conclusions.
“In general, the findings from this report lack sufficient, appropriate evidence to support the findings LPA reported,” KSDE concluded. “For this reason, findings in reference to USD 112 Central Plains and the KSDE’s audit policies and practices should be disregarded.”
LPA, however, says they did, in fact, review all information provided to them.
“We did not ignore the department’s audit documentation,” LPA said. “For the nearly 120 transcripts that had errors regarding when the student earned the credit, we carefully reviewed all documents provided by the department that supported their work.”
LPA also said they certainly did have “sufficient, appropriate evidence” for their conclusions.
“We reviewed all KSDE’s documentation related to the transcripts with timing errors,” the auditors wrote. “We reviewed transcripts for every student the district submitted credits for in the 2021-22 school year. We reviewed KCAN and additional documents from Graduation Alliance. We also worked with district and Graduation Alliance officials to understand their transcript processes and to seek clarification about student transcripts. The department disagrees with our approach, however, this audit is supported by a wealth of evidence.”
KSDE lacks credibility
History indicates the benefit of the doubt on credibility goes to Legislative Post Audit, which has a stellar reputation.
KSDE, however, does not. For example:
- A 2019 LPA audit determined that school districts were not spending At-Risk funding on above-and-beyond services for students who are academically at risk of failing, as state law requires. The State Board of Education Chair responded with a newspaper column that basically said, ‘shut up, go away, we know what we’re doing’ and denounced the audit findings.
- LPA conducted a follow-up audit in 2023 to determine what changes had been implemented. It found that school districts were still not spending At-Risk funding as required by state law.
- KSDE requires school districts to comply with state and federal law in order to be accredited, but no district has lost accreditation for violating the At-Risk spending law. KSDE rationalizes its position by claiming the At-Risk law is “not applicable” because it “is not related to school improvement.”
- Just this week, Education Commissioner Randy Watson declined to explain his contradictory statements about students who are below grade level. Watson says no students can be considered below grade level on the state assessment because the test only measures grade-level performance. One-third of students who score in Level 1 have limited ability to use and understand reading and math skills, but Watson will not acknowledge that they are below grade level. Separately, he says it is critical that students be at grade level by the third grade or they may never catch up, but he won’t explain how school districts know which students are below grade level and need remedial help.
