Cincinnati Public Schools superintendent Mary Ronan said that the district is not aware of any intentional data manipulation and respectfully disagrees with some of the report's findings.
CPS issued a complete statement in response to Yost's report, which can be read below:
On behalf of Cincinnati City School District ("CPS"), I write in response to the preliminary findings of the Auditor of State's Attendance Data and Accountability Audit. The Auditor provided these preliminary findings to CPS for the first time on Thursday, January 24, 2013.
As you know, CPS has cooperated fully with the Auditor's investigation. Over the past five months, CPS provided the Auditor's staff with direct access to review student files at CPS schools. The Auditor's staff also had the opportunity to speak directly to District personnel including testing coordinators, principals, and other staff, outside the presence of any attorney or other CPS representative. CPS has made every effort to provide files and records within the tight timelines necessitated by this audit.
Seven of CPS's 57 schools were selected for testing during the audit. We understand that the seven schools were chosen because of the high rate of mobility of students enrolled and withdrawn from those schools, and not because of any suspected impropriety in reporting attendance data. CPS consistently has one of the highest rates of student mobility in Ohio. As you know, during the 2010-11 school year, CPS processed 11,715 student withdrawals from its schools.
CPS is committed to providing the Ohio Department of Education ("ODE") and the public with accurate enrollment data for our schools.
Based on the Auditor's preliminary findings, the majority of "errors" that the Auditor observed at CPS relate to "building to building transfers." We understand that the Auditor's staff found an "error" in each case where CPS reported a break in enrollment for a student who withdrew from a CPS school and later enrolled in another CPS school. We respectfully disagree that reporting a break of enrollment or a building to building transfer necessarily constitutes an error in reporting.
Given the high mobility rate at CPS, students oftentimes stop attending school without giving school officials any information about when or where the student intends to re-enroll. When a student has not attended school for approximately two weeks, a school social worker attempts to locate the student and his/her family. If the family is located and the student does not return to school, the social worker submits a court referral for truancy proceedings and the school withdraws the student using MIS Code 71 ("Withdrew Due to Truancy / Nonattendance"). If the school social worker reports that the family has moved and/or cannot be located, the school uses EMIS Code 74 ("Whereabouts Unknown").
Students who have been withdrawn occasionally re-enroll in another CPS school, sometimes weeks or months after the student has stopped attending school. According to the Auditor, we understand that ODE would prefer that CPS cancel the student's withdrawal, and report that the student was "continuously enrolled." Without reporting a withdrawal, however, there is no way for CPS to reflect the period of time during which the student was not attending school. If no withdrawal is reported, either the student's original school must report that the student was continuously enrolled until the date of re-enrollment, or the student's new school must backdate its enrollment of the student from the time the student stopped attending the original school. Reporting the student as "continuously enrolled" does not reflect that the student was not attending school, and could also have the effect of CPS receiving public funding for a student that CPS knew was not attending school.
EMIS does not use a "continuous enrollment" rule for students who withdraw from one school district and re-enroll in a school district. For example, if a CPS student withdraws and later re-enrolls at a school in a neighboring school district, neither school must report the student as enrolled during the period of time the student was not attending school. Given that EMIS does not require "continuous enrollment" in cases of inter-district transfers, it is only logical that larger school districts not be required to report the time period of non-enrollment in cases of intra-district transfers. CPS officials have discussed this gap in the EMIS reporting guidelines with ODE for years, and we welcome further guidance and clarity from the State.
According to the findings, the Auditor's staff also found "errors" for students who were withdrawn under EMIS Code 71 ("Truancy / Nonattendance") where there was no evidence of a judicial determination of truancy. CPS is not aware of any prior interpretation by the ODE or any other state agency, suggesting that EMIS Code 71 is applicable only where a court has found a student to be truant.
On average, CPS refers more than 1,000 truancy cases per year. As we discussed with the Auditor's staff, the practice of courts in Hamilton County is to stop accepting referrals for truancy in March or April of each school year, so that the courts can handle the backlog of cases that were referred during the school year. In July, the courts wipe the slate clean so that they are prepared to accept truancy proceedings for the next school year.
There is nothing in the 2011 or 2012 versions of the EMIS manual that suggests that school districts cannot withdraw a student using Code 71 ("Truancy / Nonattendance") unless a court determines that a student was truant. CPS will follow the direction provided by ODE with respect to the use of EMIS Code 71.
CPS Is Not Aware Of Any Data Manipulation or Scrubbing
Additional "errors" found by the auditor are attributable to several forms of clerical errors. The complexity of the reporting requirements and the busy nature of many of our school offices can lead to such errors. CPS will continue to work with ODE to clarify further the EMIS reporting guidelines. CPS is committed to continue training and working with our school staffs to improve the accuracy of data reported.
CPS understands that the purpose of the Auditor's investigation was to determine whether there was any evidence that school districts were manipulating data to inflate school or district ratings. The alleged errors found by the Auditor's staff would not have changed CPS's academic rating for the 2010-11 school year. Moreover, the "errors" found by the Auditor's staff would have had no effect on the 2010-11 academic rating for six of the seven CPS schools tested: Chase (Continuous Improvement), Oyler (Continuous Improvement), Quebec Heights (Academic Emergency, now closed), South Avondale (Effective), Rothenberg (Continuous Improvement), and Virtual (Academic Watch).
CPS has examined this matter internally and found no evidence that any of its employees intentionally manipulated student data in a manner in which they knew to be improper.
We continue to believe that, at CPS at least, the broader concern involves the high level of student mobility – approximately 12,000 student withdrawals annually. Such mobility, as the Fordham Foundation noted in a recent report, negatively impacts student achievement. We believe that the need to stabilize families and decrease mobility merits a state and community focus, and we are encouraged that efforts are under way to highlight the issue in Cincinnati.
Respectfully submitted, Mary A. Ronan Superintendent