KIMBERLYEE CHAPPELL, CIA, CGAP DR.

NEIL DUGGER
Internal Auditor Interim Superintendent of Schools

AUDIT OF DISCRETIONARY DISCIPLINARY ALTERNATIVE EDUCATION PLACEMENT (DAEP)

AUGUST 11, 2009

BACKGROUND
In 1995, the 74th Texas Legislature enacted the Safe Schools Act designed to make Texas public
school safe from violent and disruptive students. It created Disciplinary Alternative Education
Programs (DAEPs) and Juvenile Justice Alternative Education Programs (JJAEPs) so that
students who were disruptive, suspended, or expelled could continue their education away from
regular classroom settings. To evaluate districts’ use of DAEPs and JJAEPs, the Disciplinary
Action Data – Student (425 Record) was added to the Public Education Information
Management System (PEIMS) to obtain the data necessary for analyzing these data 1 .
In 2007, the state began distinguishing school districts whose discretionary DAEP placement rate
(percentage) exceeded that state’s placement rate. This analysis examined the percentage of all
students placed in DAEP at the district’s discretion; as well as the African American and
economically disadvantaged (2007 only) groups. According to the discipline data reported for
the 2007 and 2008 school years, Irving ISD’s discretionary placement rate has exceeded the
state’s rate for all groups examined. The following table depicts the district’s rating and provides
a comparison with the state.
2008 2007
District Rate State Rate District Rate State Rate
All Students 2.7 1.7 2.9 1.9
African American 5.0 3.4 4.9 3.4
Economically Disadvantaged No Information 2.1 1.8
Difference Score 2.3 1.7 2.0 1.5

In summary, the district reported that 2.7% of its student population (5% of the African
American population) were removed from the traditional classroom setting and placed in the
District’s off-campus alternative education programs (i.e. Wheeler Transitional and
Development and Secondary Reassignment Centers) during the 2008 school year.
Roles and Responsibilities of 425 Coordinators
To aid in the management of the district’s disciplinary data, the 425 coordinator’s position was
created by central administration. The position was created to oversee the disciplinary records of
the campus. Principals were asked to assign an administrator for their campus, who would be
responsible for:
• Attending training (provided by central administration) on updates, and distributing the
information to their campuses,
• Reviewing the COGNOS reports for any discrepancies,
• Ensuring the integrity of the data input into Student Plus, and
• Addressing any PEIMS errors found during submissions.
1
2008 Discipline Data Validation Manual

1
Throughout the school year, central administration forwards COGNOS reports to the 425
coordinators which summarize all incidents input into Student Plus by the campus. In addition,
four error reports are also forwarded to the 425 coordinator. These reports should be reviewed
and corrected to ensure that data submitted to the TEA is accurate.

OBJECTIVES, SCOPE AND METHODOLOGY

The intent of the audit is to examine the disciplinary records, and ultimately:
• Obtain an understanding of the district’s high discretionary placement rate of its African
American student population; and
• Determine whether disciplinary actions are equitably administered to the District’s ethnically
diverse student population.
To achieve these objectives, Internal Audit (IA) reviewed the 425 records for all campuses
(through March 31, 2009). The data from these records were used in determining the district’s
discretionary placement rate for the 2009 school year (using enrollment as of the 1/9/2009
snapshot date). The formula used by the state in calculating the Discretionary DAEP Placement
Rate is a follows:
Discretionary Placement Discretionary number of discretionary DAEP placements of students for the
Rate (all students or = school year (all students or African American students)
African American students) District number of students (all or African American) in attendance in school year

This formula only takes into account students removed from the campus and placed in the
district’s off campus alternative education programs. In addition, it only includes those incidents
in which the campus administrators have the discretion to determine the disciplinary action taken
against the student.
During Internal Audit’s testing, this formula was applied to all ethnic groups, to determine
whether any other ethnic group’s placement rate exceeded the district’s overall rate and the
state’s rate (from prior school years). In addition, the following testing of disciplinary data was
performed:
• Calculation of discretionary DAEP placement for each campus,
• Analyses of ethnic group placement for all disciplinary actions (i.e. In-School Suspension,
Out-of-School Suspension, etc.),
• Brief analyses of the integrity of disciplinary data records, and
• Comparison of the average number of days ethnic groups are removed from the classroom
setting.
Scope Limitations
At the initiation of audit test work, it was noticed that the discipline data was incomplete (i.e. one
campus had not reported any data for the entire school year as of March 2009). Although the
425 coordinators were informed of the impending audit, and were given multiple opportunities to
review (and correct) data input into Student Plus, Internal Audit’s review revealed numerous
errors. Due to the time constraints, the campus with the largest number of questionable items
was contacted. Although some of these issued were corrected by resubmission, complete
reliance can not be placed on the data submitted to PEIMS.

OVERALL CONCLUSION
Based on the test work performed Internal Audit has concluded that insufficient monitoring is
being performed at the campus level to ensure the integrity of the data submitted to the state to

2
calculate the district’s placement rate (for both the overall district and the African American
group). Numerous errors were discovered in the data reported for the 2009 school year, which
should have been detected during the reviews performed by the campus’ 425 coordinator. In
addition, it appears processes are not sufficient at the campus level to ensure that errors (i.e.
duplications) will not occur. Lastly, the Student Plus system is not designed with controls to
ensure that data input by the campuses is logical.
In regards to analysis of IISD’s discretionary DAEP placement rates, IA’s calculation is
consistent with the previous school years. It appears that 2009 African American discretionary
placement rate (5.1) will exceed the district’s placement rate for all students (2.7). The
additional testing performed on the remaining ethnic groups further reveals the African
American is the only ethnic group whose placement rate exceeds the district’s overall placement
rate.

RECOMMENDATION
It is recommended that the disciplinary process become standardized throughout the district.
Although it is customary for campuses to design the processes for documenting disciplinary
actions, it appears that this current method does not ensure the integrity of the data reported in
PEIMS. In addition, it appears that the integrity of our attendance data is also impacted, which if
tested during the TEA visit, could result in possible assessments against the district’s state
funding. 2
Central and campus administration should coordinate their efforts to improve the district’s data
quality. Possible actions could include the following:
• Create standardized procedures for the 425 coordinators, which will provide guidance on
performing their duties, and ensure consistency in the process.
• Standardize the documentation required for disciplinary data. This could include
consolidating the district’s safeguard form with campus forms.
• Implement deadlines for updating the disciplinary records and submitting corrections for the
reports sent to the 425 coordinators.
• Require all 425 coordinators and the data entry clerks to attend the required training.
• Require more specific incident information to be input into the system.
• Incorporate the responsibilities of the discipline administrators into their annual evaluations.
• Obtain a database which will perform data validation and reasonableness checks. The
current system allows erroneous, incomplete or invalid information to be input. For example,
incident dates and actions dates could be any date (i.e. dated entered from 2006/2007 school
year, or any day (Saturday, Sunday, or holiday), or be left blank in the database.)

MANAGEMENT’S RESPONSE
Central and campus administration will coordinate their efforts to address the recommended
actions presented in the discipline internal audit:
• Establish a task force of twelve (12) campus discipline 425 Coordinators to hear the audit
report and draft a plan of action to address the issues presented in the discipline audit.
The Task Force will meet on August 10, 8-10:00 A.M., Board Conference Room; August
12, 1-3:00 P.M., TR 3; and if needed, August 14, 8-10:00 A.M., TR 1. A discipline
handbook will be developed to include standard procedures and forms that will ensure
consistency in the process and data integrity.

2
TEC, §42.255, 19 TAC §129.21(m)

3
• Present findings of the discipline audit to all principals at the general principals’ meeting
on September 1.
• Conduct discipline accounting training for all discipline administrators on September 10,
15, and 17.
• Monitor the progress of the plan every six weeks throughout the school year. As designed
by the task force.

4
OBSERVATIONS
Review of Discretionary Alternative Education Placement (DAEP)
Internal Audit reviewed the 2009 disciplinary data to determine whether the trend, identified by
the state, continued for the current school year. Using the 1/9/2009 enrollment snapshot, the
placement rates for the district, as well as the placement rates for all ethnic groups, were
calculated. For disciplinary data reported as of 3/31/09 the African American discretionary
DAEP placement has again exceeded the district’s rate. In fact, the African American group is
the only ethnic group whose placement rate exceeded the district’s rate. The placement rate for
the overall district was 2.7 (excluding early childhood campuses). This rate exceeds the 2007
and 2008 state rate for all students (1.9 and 1.7 respectively), and is consistent with IISD’s rates
for the same years (2.9 and 2.7 respectively).
American African
Asian Hispanic Caucasian
Indian American
District Rate 2.7
Placement Rate 1.1 0.5 5.1 2.4 2.3
Difference Score (1.6) (2.2) 2.4 (0.2) (0.4)

Comparison of Discretionary Placement by Ethnic Group Population

The following chart depicts the disciplinary actions assigned to the different ethnic groups, as
compared to the ethnic makeup of the entire student population. As shown, when compared to
their representation of the population, African American students are significantly
overrepresented in all types of placements.

100% 2% 1% 1% 1% 0%
4%

90% 13% 24%

23% 26%
29%
80%
15%
70% 13% 13%
15%
12%
60%
Asian
100%
50% African American
Caucasian
40%
68% Hispanic
62% 62%
30% 57% 58%

20%

10%

0% 0%
All Students Expel/JJAEP ISS (8,625) OSS (2,083) AEP (824) SpEd AEP (3)
(31,072) (42)

5
Comparison of DAEP Placement Rates
All Campuses
Testing was further extended to identify those campuses with placement rates that exceeded the
district or comparable campuses. The results are summarized below.
• All Campuses/All Ethnic Groups
For the 34 campuses tested (early childhood were excluded), twenty-nine percent of the
campuses’ DAEP placement rates exceeded the district’s rate of 2.7. All ten were
secondary campuses.
• Secondary Campuses/All Ethnic Groups
The placement rate for the 13 secondary campuses was 4.8. Six of the 13 (46%) campuses
exceeded this rate.
• Elementary Campuses
The placement rate for the 21 elementary campuses was 0.4. Five of the 21 (24%)
campuses exceeded this rate.

Comparison of Ethnic Group Placement Rates

The placement rates were calculated for the individual campuses/clusters, and compared to the
placement rate for each ethnic group for that campus/cluster. The results are summarized in the
following tables. This testing proves that over one-half of the campuses’ placement rates exceed
the campus’ rate of DAEP placement for African American students. However, the campus with
the largest difference between rates is Irving High. Incidentally, this campus represented
approximately 50% of the errors found during IA’s cursory review (see Data Integrity section
below.)
• Secondary Ethnic Group Comparison
The placement rate for each campus was calculated and compared against the ethnic group
placement rate for the same campus. The percentage of discretionary DAEP placement for
African American students was more than double the placement of the Hispanic and
Caucasian groups at the secondary campuses.

American African
Asian Hispanic Caucasian
Indian American
# of campuses whose placement rate
exceeded the overall secondary DAEP 0 0 10 3 5
placement rate
% of secondary campuses 0% 0% 77% 23% 38%

• Elementary Ethnic Group Comparison

The placement rate for each campus was calculated and compared against the ethnic group
placement rate for the same campus. The discretionary DAEP placement of African
American students exceeded the overall placement for elementary campuses for 52% of the
campuses.

American African
Asian Hispanic Caucasian
Indian American
# of campuses whose placement rate
exceeded the overall elementary DAEP 1 1 11 1 7
placement rate
% of elementary campuses 5% 5% 52% 5% 33%

6
 • Cluster
Comparison of placement rates between clusters reveals that the African American
placement rate in the Central cluster (6.7) exceeded the overall placement rate for all
African American students (5.1); and the placement rate for the other two clusters. This
rate seems high when African American students represent only 11% of the Central
cluster’s population (compared to 23% of the North cluster).
In addition, the placement rate for African Americans exceeded the district’s overall rate
(2.7) for all three clusters and the Academy of Irving ISD.
American African
Asian Hispanic Caucasian
Indian American
Placement Rate 0.0 1.0 6.7 2.4 2.1
Central (Irving)
% of Population 0% 3% 11% 73% 13%
Placement Rate 0.0 0.3 4.9 2.5 2.4
North (MacArthur)
% of Population 0% 6% 23% 50% 20%
Placement Rate 3.1 0.3 4.3 2.5 2.3
South (Nimitz)
% of Population 0% 4% 8% 66% 21%
Academy of Irving Placement Rate 0.0 0.0 5.0 2.2 12.0
ISD % of Population 0% 7% 8% 70% 15%
Union Bower Placement Rate 0.0 0.9 0.8 1.3 1.4
Center % of Population 0% 0% 9% 80% 11%

Comparison of Length of DAEP placement by Ethnic Group

To determine whether equitable treatment was applied across ethnic groups when students were
removed from the instructional setting, Internal Audit compared the number of days a student
was removed from the classroom for each incident codes. In addition, this testing was applied to
those students who had multiple offenses (two and three incidents). (Refer to Attachment A)
As depicted in the attached tables, for the three largest ethnic groups (African American,
Hispanic and Caucasian), the deviation was not greater than .5 days for those students with one
or two incidents. However, for students with three incidents, African American students
exceeded the Hispanic group by 1.6 days and the Caucasian group by 3.1 days.
Overall, the Hispanic students incurred the greatest average number of days per incident(s),
when compared against comparable incidents for the African American and Caucasian students.

Removal from the Instructional Setting

Internal Audit compared the removal of students from the instructional setting (out of school
suspension). Based on the comparison, on the average Caucasian and Hispanic students were
removed from the instructional setting more than the other ethnic groups.

American African
Asian Hispanic Caucasian
Indian American
Days of Out of School Suspension 8.0 65.0 1,642.5 3,324.5 954.5
Number of incidents 8 34 910 1,627 466
Average Day(s) per Incident 1 1.9 1.8 2.04 2.05

Data Integrity
Internal Audit tested the reasonableness and reliability of the data entered into Student Plus
(which is ultimately reported to the TEA) and the attendance data recorded for the disciplinary

7
actions taken during the school year. The purpose of these tests was to test the accuracy of the
data recorded in Student Plus, and ultimately reported to the TEA.
Reliance can not be placed on the Discipline Data
Upon scanning the discipline records for the district (Excel format), the auditor found numerous
discrepancies. It should be noted that these discrepancies were found reviewing an EXCEL
spreadsheet provided by the PEIMS Department.
• A single incident was entered more than once into Student Plus, under different incident
number. Therefore, the number of incidents reported to the state was increased.
• Incident dates and action dates were erroneous entered in the system. Campuses recorded
incidents as occurring on the weekend, or on student holidays.
• Actions against students were entered into the discipline database more than once (under a
single incident).
Disciplinary Actions are not supported by Student Attendance Data
Attendance data in the Student Plus system did not accurately reflect the disciplinary actions
recorded on the 425 records. Disciplinary action for 154 students (8 secondary campuses) was
compared against the attendance recorded in Student Plus. Attendance for 55 actions (36%) did
not agree to disciplinary action assigned by the campus. The following errors were encountered:
• Disciplinary action reported in the attendance database could not be traced to an incident in
the discipline database.
• Students’ attendance in Student Plus did not reflect the removal from the classroom (ISS,
OSS)
• Funded absences were recorded as non-funded absences (i.e. ISS placements recorded as
unexcused absences).
• The dates the students were assigned to DAEP did not agree with the days students were
marked absent from the classroom.
• The supporting documentation for the disciplinary action did not agree to the data input
into Student Plus for incident dates and action start dates.
• A student was marked absent (ill) for all courses on the incident date.

Auditor’s Note: IA review of the records was not an in-depth review. Excel tools were used to
test the reasonableness of the data. More intensive review will be required of the campuses to
determine the extent of inaccuracies reported in 425 records.

8
 REPORT DISTRIBUTION

Lane Ladewig Division Director Campus Operations

Dr. Alice Owen Executive Director of Technology
Dr. Abby Melton Program Director - PEIMS
Dr. Neil Dugger Interim Superintendent of Schools

9
 ATTACHMENT A
Students with One Incident
American Indian Asian African American Hispanic Caucasian
Incident # of # of # of # of # of # of # of # of # of # of
Average Average Average Average Average
Days Students Days Students Days Students Days Students Days Students

01 0.0 0 - 0.0 0 - 3.0 3 1.0 6.0 5 1.2 0.0 0 -

20 0.0 0 - 0.0 0 - 340.0 9 37.8 304.0 6 50.7 88.0 2 44.0
21 9.0 5 1.8 186.5 60 3.1 1,162.5 475 2.4 3,952.0 1497 2.6 960.0 360 2.7
22 0.0 0 - 0.0 0 - 0.0 0 - 0.0 0 - 3.0 1 3.0
33 0.0 0 - 0.0 0 - 0.0 0 - 0.0 0 - 3.0 1 3.0
41 0.0 0 - 5.0 2 2.5 179.0 16 11.2 765.0 56 13.7 104.0 12 8.7
50 0.0 0 - 0.0 0 - 0.0 0 - 91.0 8 11.4 38.0 3 12.7
Overall
Average 1.8 3.1 3.3 3.3 3.2

Students with Two Incidents

American Indian Asian African American Hispanic Caucasian
Incident # of # of Average # of # of Average # of # of Average # of # of Average # of # of Average
Days Students Days Days Students Days Days Students Days Days Students Days Days Students Days

01 01 0.0 0 - 0.0 0 - 2.0 1 2.0 0.0 0 - 0.0 0 -

01 21 0.0 0 - 0.0 0 - 4.0 2 2.0 41.0 7 5.9 0.0 0 -
10 21 0.0 0 - 0.0 0 - 0.0 0 - 4.0 1 4.0 0.0 0 -
20 20 0.0 0 - 0.0 0 - 0.0 0 - 50.0 1 50.0 0.0 0 -
20 21 0.0 0 - 0.0 0 - 0.0 0 - 317.0 7 45.3 8.0 1 8.0
20 50 0.0 0 - 0.0 0 - 22.0 1 22.0 0.0 0 - 0.0 0 -
21 21 59.0 3 19.7 61.0 13 4.7 1,023.0 200 5.1 2,520.3 496 5.1 650.0 115 5.7
21 22 0.0 0 - 0.0 0 - 22.0 1 22.0 0.0 0 - 0.0 0 -
21 33 0.0 0 - 0.0 0 - 0.0 0 - 21.0 1 21.0 0.0 0 -
21 41 0.0 0 - 0.0 0 - 178.0 10 17.8 308.0 18 17.1 67.0 9 7.4
21 50 0.0 0 - 0.0 0 - 0.0 0 - 91.0 2 45.5 29.0 1 29.0
41 41 0.0 0 - 56.0 1 56.0 0.0 0 - 0.0 0 - 23.0 1 23.0
Overall
19.7 8.4 5.8 6.3 6.1
Average
 ATTACHMENT A

Students with Three Incidents

American Indian Asian African American Hispanic Caucasian

Incident # of # of Average # of # of Average # of # of Average # of # of Average # of # of Average

Days Students Days Days Students Days Days Students Days Days Students Days Days Students Days

01 21 21 0.0 0 - 0.0 0 - 32.0 1 32.0 6.0 1 6.0 0.0 0 -

10 21 21 0.0 0 - 0.0 0 - 0.0 0 - 5.0 1 5.0 0.0 0 -
20 20 20 0.0 0 - 0.0 0 - 59.0 1 59.0 0.0 0 - 0.0 0 -
20 20 21 0.0 0 - 0.0 0 - 0.0 0 - 83.0 1 83.0 0.0 0 -
20 21 21 0.0 0 - 8.0 1 8.0 315.0 4 78.8 313.0 6 52.2 93.0 1 93.0
2,613.
21 21 21 23.0 4 5.8 48.0 7 6.9 827.0 95 8.7 5 291 9.0 629.5 76 8.3
21 21 41 0.0 0 - 0.0 0 - 149.0 6 24.8 461.0 16 28.8 20.0 1 20.0
21 21 50 0.0 0 - 0 0 - 0.0 0 - 61.0 2 30.5 28.0 1 28.0
21 41 41 0.0 0 - 0 0 - 0.0 0 - 67.0 2 33.5 0.0 0 -
Overall
5.8 7.0 12.9 11.3 9.8
Average
 KIMBERLYEE CHAPPELL, CIA, CGAP DR. NEIL DUGGER
Internal Auditor Interim Superintendent of Schools

Audit Follow-Up Report

Discretionary DAEP Placements
May 12, 2010
“The District has made a concerted effort to address the disproportionate rate of African Americans
assigned to alternative education for discretionary incidents; however data integrity continues to be a
risk.”

Executive Summary the campus level to ensure the integrity of the

At the request of the Finance Committee of the
Board of Trustees, the discretionary disciplinary
alternative education placements were examined
for the first semester of the 2009/2010 school
year.
It appears that the actions taken by Irving ISD to
address the high placement of African American
students have been effective. However, the
District has not fully addressed its data integrity
issues. Internal Audit found high error
percentages in the attendance and disciplinary
data reported in the student information system.
Background
In August 2009, Internal Audit issued the audit
report Audit of Discretionary Disciplinary
Alternative Education Program (DAEP)
Placements. The objectives of the audit were 1)
to obtain an understanding of Irving ISD’s (the
District’s) high discretionary placement rate of
its African American student population, and 2)
to determine whether disciplinary actions were
equitably administered to the District’s
ethnically diverse student population. The audit
found that the placement rate for African
American students not only exceeded the
District’s placement rate for the same period,
but it was the only ethnic group that exceeded
the District’s rate. In addition, the audit found
insufficient monitoring was being performed at
disciplinary and attendance data submitted to
the State. Management was in general
agreement with the report and agreed to
implement corrective actions to address the
Internal Audit’s findings.
Scope and Methodology
The objective of this follow-up review was to
determine how the District had progressed in
implementing corrective actions. The
placement rates for the District and all ethnic
groups were calculated using the disciplinary
data for the first semester of 2009/2010 school
year. Interviews and meetings were held with
central and campus administration regarding the
current procedures. Supporting documentation
was reviewed to verify the accuracy and
integrity of the data reported to the PEIMS
department, and ultimately the State.
Furthermore, the scope of this follow-up audit
was expanded to examine whether any
individual’s referral of African American
students appeared excessive or questionable.
Based on the data recorded in the student
information system, Internal Audit scrutinized
whether any teacher’s removal of African
American students could be deemed biased or
racially motivated.
Discretionary DAEP Placements
Audit Follow-Up
Page 1 of 4
This audit was conducted in accordance the decreased between the 08/09 and 09/10 school
Institute of Internal Auditor’s International years. The African American placement rate
Professional Practices Framework. still exceeded the District’s rate, however, the
difference between the two periods decreased
Accomplishments immensely.
Since the issuance of the audit report, it appears Comparison of DAEP Rates
that the District has made a concerted effort to 08/09 09/10 Difference
address the disproportionate rate of African District 2.7 1.3 (1.4)
Americans assigned to alternative education for American Indian 1.1 0.0 (1.1)
Asian 0.5 0.6 0.1
discretionary incidents. In fact, it appears that
African American 5.1 1.6 (3.5)
all disciplinary placements for African Hispanic 2.4 1.3 (1.1)
American students have decreased from the Caucasian 2.3 1.4 (0.9)
08/09 to 09/10 school years (first semester data
compared for both periods). Factors Contributing to the Decreased
African American Discretionary Placements Placements
(1st Semester) According to management, several factors have
Percentage
contributed to the dramatic decrease in
08/09 09/10 Chage
discretionary placements. Internal Audit
Expulsions/JJAEP 6 1 -83%
believes that these factors, and the actions taken
ISS 1280 924 -28%
OSS 331 227 -31% by central administration, brought about a
DAEP 124 67 -46% district-wide awareness and change in the
handling of not only African American students,
Although the African American group is still but to the entire student body.
overrepresented in discretionary placements for
in school suspension, out of school suspension Passage of HB 171
and discretionary alternative education House Bill 171 required that consideration be
placements, the gap between its representation given to mitigating factors in determining the
in placements type and population has decreased disciplinary action taken against a student.
from 6% -10% to (3%) – 6%. Instead of having a zero tolerance policy,
districts should consider such factors as self-
09/10 Discretionary Placement of Students by Ethnic Group
1st Semester Only
defense, intent, disciplinary history, or a
1% 2% 2%
disability, before suspending, expelling or
100% 4%

13%
10%
19% 17% 16%
removing a student to an alternative education
90%
10%
program.
80%
14% 10% 16% American Indian
70%
14% 16%
Asian Emphasis of a “Positive Proactive Approach to
African American
60% Caucasian Discipline”
Hispanic

50%
The District stressed the value of keeping the
40%
student in the classroom. Best practices were
68% 70%
67%
30%
65% 65%
shared among campus administrators in
20%
administering disciplinary actions other than
10%
removing the student from the instructional
0%
setting. Based on interviews with campus
All Students Expel/JJAEP (10) ISS (4,851) OSS (1,309) DAEP (423)
(31,864) administrators, more are assigning students to
See Attachment A for larger view Friday after-school detention or Saturday
DAEP Rate Calculation School.
The discretionary placement rates for the
District and the three largest ethnic groups
Discretionary DAEP Placements
Audit Follow-Up
Page 2 of 4
Tone at the Top – Resolution No. 09-10-08
The Board of Trustees adopted Resolution No.
09-10-08 in November 2009, which
implemented strategies to “eliminate any
disproportionate imposition of discipline or
assignment to alternative educational programs
due to or resulting from the student’s race,
color, national origin, by the end of the 2010-
2011 School Year”.
African American Discretionary Referrals
There were 1,072 discretionary referrals for
African American students which resulted in the
student being removed from the instructional
setting. According to the student information
system, 60% of the referrals were made by
teachers (including substitutes) and
paraprofessionals. The remaining 40% were
made by campus administrators, police officers,
and campus auxiliary officers.
On the average, however, there were 1.85
referrals for every teacher/paraprofessional, but
7.7 referrals for every campus administrator,
police officer or campus auxiliary officer.
Assuming the data recorded in the student
information system is accurate, campus
administrators (not teachers) are initiating the
disciplinary actions which have resulted in
African American students being removed from
the instructional setting.
Further examination of the referrals made by
teachers also revealed that those teachers with
the highest number of referrals resulted from
repeat offenders. For example, the teacher with
the highest African American referrals resulted
for one student being referred thirteen times. In
fact, those teachers with the most referrals
resulted from one to three students being
referred more than once. The most students
referred by one teacher were five elementary
students which resulted in seven referrals.
Significant Remaining Risks
Actions are still needed to improve the integrity
of disciplinary and attendance data reported by
the campuses. It appears that the efforts made
by central administration (i.e. additional training
and labs and the standardization of the
discipline form) have not fully addressed the
issues resulting in poor data quality. (Refer to
Attachment B)
Disciplinary Data
Internal Audit examined seventy-two percent of
the discipline records (315 out of 435):
 Erroneous data was found in seventy-five
percent (72%) of the records reviewed.
 Three percent (3%) of the records were
duplications or errors.
A review of a report created by the
Reassignment Center (RAC) revealed that 13
students were placed in AEP, but disciplinary
records were not created for the students by the
home campuses.
Attendance Data
In addition, attendance errors were noted during
the review. Attendance was reviewed for 225
incidents.
 Errors were noted for 48% of the incidents.
The errors included both an underreporting
and over-reporting of Average Daily
Attendance (ADA).
 Numerous teachers were not reporting
attendance on a daily basis (i.e. students
assigned to RAC were not marked absent by
the teacher).
 Some attendance clerks misunderstood the
District’s procedures for students assigned
to AEP, or failed to update the attendance
for students assigned to AEP.
Inadequate Follow-Up for Carryover Students
Approximately 30 of the erroneous 425 Records
resulted from the home campus’ failure to
follow up on students who did not complete
their AEP placement from the prior school year.
Campuses have the option to require a student
who does not serve all days assigned to AEP, to
report the following school year.
Discretionary DAEP Placements
Audit Follow-Up
Page 3 of 4
Additional Recommendations
In addition to recommendations made in the
original report, Internal Audit also recommends
the following.
1. Assigning the responsibility of updating to
RAC
Based on interviews with campus personnel,
once the student has been assigned to the
RAC, the home campus is not aware of the
student’s activity. For example, numerous
errors existed because the student failed to
report to RAC on the day originally
assigned.
Since the RAC is aware of all activity once
the student has reported to the campus, this
should increase the integrity of the data
entered for discipline and attendance.
2. Creating an additional attendance clerk
position for the RAC
The process for recording attendance at the
RAC differs from traditional campuses. The
teacher manually records the attendance for
his/her classroom, which is given to the
attendance clerk to manually record on an
attendance log for the twelve secondary
campuses. The attendance clerk updates any
absences in the student information system.
The home campus is responsible for
updating the system to denote the student is
present at the RAC.
To streamline into a more efficient process,
Internal Audit recommends hiring another
attendance clerk, who could assist the
current attendance clerk in recording all
attendance for the RAC, and also assist in
updating the disciplinary data.
3. Discontinuing or minimizing the practice
of overlapping discretionary AEP across
school years
Since numerous errors resulted from those
students whose placements overlapped
school years, Internal Audit recommends
minimizing this practice to those students
with mandatory placements, or those
considered unsafe to return to the campus.
4. Providing a more effective communication
channel between the home campus and
RAC
The communication channels between the
RAC and the secondary campuses have not
been optimized to ensure that student data is
accurately updated and reported. Internal
Audit recommends that District
administration coordinate efforts between
these campuses to reduce the errors found
during this audit.
Management’s Actions
Management has agreed that shifting the
responsibility of updating of all attendance
information, and the disciplinary records, to
Reassignment Center would be more efficient
and should result in more accurate data. Mr.
Ladewig will handle the movement of these
responsibilities to the Reassignment Center. Dr.
Melton and Dr. Owen will work with the
Reassignment Center in using the available
technology to more efficiently update the
student information system.
Anticipated Timeline: 2010/2011 School Year
In addition, on May 10, 2010, central
administration received guidance on proper
attendance practices from the Texas Education
Agency’s (TEA) Director of Forecasting and
Fiscal Analysis. According to the TEA,
teachers are responsible for reporting the
attendance in their classrooms, despite
information that the student could be in other
setting (i.e. DAEP, ISS, school activity, nurse’s
office, etc). This information was shared with
the principal and the attendance/data entry
clerks.
Discretionary DAEP Placements
Audit Follow-Up
Page 4 of 4
Report Distribution
Dr. Neil Dugger
Interim Superintendent
Dr. Marie Morris
Asst. Superintendent – Teaching & Learning
Lane Ladewig
Division Director – Campus Operations
Dr. Alice Owen
Executive Director - Technology
Dr. Abby Melton
Program Director - PEIMS
Board of Trustees Finance Committee

Discretionary DAEP Placements

Audit Follow-Up
Page 5 of 4
 ATTACHMENT A

09/ 10 Discretionary Placement of Students by Ethnic Group

1st Semester Only

100% 1% 2% 2%
4%
10%
13% 19% 17% 16%
90%
10%

80% American Indian

14% 10% 16%
14% 16% Asian
70% African American
Caucasian
60% Hispanic

50%

40%
68% 70% 67%
65% 65%
30%

20%

10%

0%
All Students Expel/JJAEP (10) ISS (4,851) OSS (1,309) DAEP (423)
(31,864)
 ATTACHMENT B

Adjustments
Accuracy of Discipline Records Attendance Testing (Errors in ADA Period)
Funded Unfunded
% of % of Absence Absence
% of Erroneous
% of Records % of Records Records Attendance Attendance reported as reported as Error May
Total Not Sample Accurately Partially % of Records (Duplications/ Sample % of Reported Not Reported Unfunded Funded Not Impact
Loc# Campus Pop Tested Size Updated Updated Not Updated Overlaps/Errors) Size Population Accurately Accurately Absence Absence Funding
002 Irving HS 102 0 102 14% 38% 43% 5% 40 39% 70% 30% 6 3 3
003 MacArthur HS 95 39 56 63% 16% 20% 2% 45 47% 87% 13% 1 3 2
004 Nimitz HS 50 25 25 12% 52% 36% 0% 16 32% 63% 38% 0.5 4.5 1
005 UBCL 4 0 4 50% 50% 0% 0% 3 75% 0% 100% 3
006 Academy HS 16 7 9 33% 44% 22% 0% 9 56% 44% 56% 2 3
041 Bowie MS 37 11 26 8% 54% 31% 8% 23 62% 26% 74% 4.5 1.5 11
042 Crockett MS 10 0 10 30% 50% 20% 0% 10 100% 20% 80% 8
043 Travis MS 22 6 16 25% 56% 13% 6% 15 68% 0% 100% 1.5 1.5 12
044 Lamar MS 9 0 9 22% 67% 11% 0% 9 100% 0% 100% 1 8
045 Austin MS 16 7 9 11% 56% 33% 0% 7 44% 86% 14% 1
046 Houston MS 32 14 18 22% 67% 11% 0% 18 56% 0% 100% 18
048 de Zavala MS 27 11 16 13% 56% 31% 0% 15 56% 93% 7% 1
102 Brown ES 3 0 3 33% 33% 33% 0% 3 100% 67% 33% 1
103 Britain ES 1 0 1 0% 0% 100% 0% 1 100% 100% 0%
105 Good ES 3 0 3 0% 33% 67% 0% 3 100% 33% 67% 1 1
106 J. Haley ES 1 0 1 100% 0% 0% 0% 1 100% 0% 100% 1
107 T. Haley ES 1 0 1 0% 0% 100% 0% 1 100% 0% 100% 1
109 Keyes ES 1 0 1 0% 100% 0% 0% 1 100% 100% 0%
113 Farine ES 1 0 1 0% 100% 0% 0% 1 100% 0% 100% 1
114 Schulze ES 1 0 1 0% 0% 100% 0% 1 100% 0% 100% 1
121 Davis ES 1 0 1 0% 100% 0% 0% 1 100% 100% 0%
122 Gilbert ES 1 0 1 100% 0% 0% 0% 1 100% 100% 0%
124 Stipes ES 1 0 1 0% 100% 0% 0% 1 100% 0% 100% 1
435 120 315 25% 42% 30% 3% 225 52% 52% 48% 18.5 13.5 77