Reply to Rulemaking on residency fraud: Comment now!

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[quote=Anonymous]4. We recommend that OSSE comply with the Act and
spend from the Residency Fund to support timely
investigations.
Pursuant to law, the Residency Fund shall be used to fund
enforcement activities concerning student residency verification. In
addition, OSSE requested in communications to DCPS and PCS that
an investigation be conducted within 30 days of tip referral. We
found that the Residency Fund had not been used and OSSE did not
have a budget for its planned use. We determined that investigations
generally took between 100 and 200 days. As a result of the lack of
investment in investigations, non-resident students may have taken
educational opportunities from eligible resident students during the
investigation period, which could extend into the subsequent school
year.
In conjunction with our testing, our research revealed that the
District’s investigative staff to student ratio was weak when
compared to certain jurisdictions. Particularly, one jurisdiction had
15 staff who investigated residency fraud for approximately 180,000
students and the other had 40 staff for approximately 150,000
students. It is important to note that in both cases the staff had other
duties such as investigating student attendance; however, the staff to
student ratio still outweighs the District’s even after reducing the
staff number in half. Figure 4 compares the student populations and
investigative staff of the District and the two neighboring
jurisdictions.
Comparison of Local Student Populations and Investigative
Staff
Jurisdiction # of Investigative
Staff # of Student Population
Neighboring School
District A 15 (part-time) ~180,000
Neighboring School
District B 40 (part-time) ~150,000
District of
Columbia
DCPS: 1 (full-time)
PCSB: contracted
private
investigator(s)
~46, 000 DCPS
~33,000 PCS
OSSE noted that they have not used the Residency Fund because it
was less than a year old. However, both PCSB and DCPS stated that it
was impossible to conduct investigations within 30 days given their
limited resources and staff relative to the number of allegations.
DCPS had only one full-time investigator and PCSB contracted with
an investigative firm on an as-needed basis.
Lack of investment
in residency fraud
investigations
resulted in
investigations on
average taking
longer than 100
days and in many
cases more than 200
days
Figure 4
The Residency Fund
had not been used
and OSSE did not
have a budget for its
planned use
Audit of Non-District Resident Students Enrolled in Public Schools
Office of the District of Columbia Auditor
September 30, 2013 Page 16
We recommend that OSSE establish a budget to expend funds from
the Residency Fund to support verification efforts such as
investigations. Allowing the Residency Fund to accumulate and not
be used for intended purposes, potentially increases the risk of
noncompliance with the Act and decreases the Program’s overall
effectiveness and efficiency[/quote]

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