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Rest of the Story: CDE Audit

The Douglas County School District (DCSD) is working to resolve a dispute with the Colorado Department of Education (CDE), which claims that some of our full-time students did not meet the State’s requirements to receive full-time funding.

Just the Facts
The audit conducted by CDE reported that 1,335 DCSD students did not meet its “seat time” requirements, necessary to be considered “full-time” during the 2012-2013 and 2013-2014 school years. While 1,250* (94 percent) of the students (now graduates) in question were scheduled and attended school full-time, CDE objected to the adequacy of the District’s documentation.

*DCSD does not dispute the remainder of the students (115) captured in the audit that were far under the required time.

On June 23, 2015, CDE notified DCSD that those students would be reclassified to part-time and their funding would be reduced by half to part-time levels. As a result, the District would be required to reimburse the State $4.2 million.

DCSD has worked diligently to provide the State with additional documentation and is currently engaging in discussions in good faith to reach a resolution.

DCSD is one of the lowest-funded school districts in Colorado. To make matters worse, during the 2012-2013 and 2013-2014 school years, the state underfunded DCSD by millions of dollars and as a result we faced significant budget reductions.  During that same period, our high school class sizes increased to unacceptable levels.

The then high school leadership team, which included principals, decided that the best way to solve this problem, while facing significant budget cuts was to ask high school teachers to teach six sections (6-of-8) instead of five (5-of-7) each semester.  This added more than 100 sections per semester to our high schools, allowing the schools to:

  1. Reduce class sizes to 30 students
  2. Maintain their elective offerings
  3. Reduce budgets without decimating our elementary and middle schools, where the impact of cuts would be far more acute.

The change in schedule wasn’t to blame
While some believe the 6-of-8 schedule is to blame for the audit findings, this is not the case.

Schools across the state, including DCSD’s own Castle View High School, have successfully utilized 6-of-8 schedules for years, and as shown in the audit, other DCSD schools implemented the schedule between 2012-2014, without issue.

Every DCSD school was working diligently to ensure students met their requirements, based on their understanding of CDE’s regulations. The schedules were reviewed annually and the Student Data and Records department offered feedback.

What Happened?
The dispute with the State centers on the documentation DCSD provided, because of two issues:

The determination of whether a student meets the full-time requirement is based on their first semester schedule as of CDE’s October student count day (October 1). Their second semester schedule may have balanced the time requirement, but CDE does not take this into consideration.

Additionally, many of the students involved graduated with above-average credits, exceeding DCSD’s graduation credit requirement, which is higher than the state’s. Again, CDE does not take this into consideration.


Advisement Attendance Documentation
As had been done in previous years, seniors were placed in an advisement class, which focused on providing personalized support to ensure academic and post-secondary success. As an example, students at Mountain Vista High School participated in the SOAR program, which serves as advisement, providing academic support, career and college planning and course selection.

Despite no changes in bell schedule or structure, CDE chose not accept documentation for the second year of the SOAR because, according to the Department:

  1.  The course was not assigned a room
  2. The school did not provide adequate attendance records
  3. The students did not receive a grade on their transcript for the class.


Next Steps
Upon learning of the issue and the clarification offered by CDE, DCSD immediately implemented changes.

Concurrently, the District worked closely with CDE to provide additional evidence that the students in question were indeed full time students.

Additionally, through the available appeal process, DCSD asked for a significant reduction or complete waiver of the fine associated with this allegation.

Reasons for reduction or waiver:

  1. The so-called lost time is marginal. Even by CDE calculation, the so-called lost time is marginal. The audit showed that these students averaged 96.7% of the required seat time, making it illogical and unreasonable for CDE to reduce annual funding for those specific students by half.
  2. DCSD was not made aware of the CDE claim regarding the 2012-13 school year until February 2014 -- nearly three-quarters into the following school year.
  3. One-third of District funding is provided by local tax dollars, so DCSD believes any refund should be reduced by a third. 

Then CDE Commissioner Richard Hammond chose not to use his discretion, although he has previously done so for other school districts.

DCSD's Position
DCSD remains committed to resolve the issue amicably with CDE, in the best interest of the DCSD students. If this is not possible, DCSD plans to use every legal pathway to ensure the money remains in our high schools.

Additional Resources
Press Release