Afton Completes Title I Review with Arizona Department of Education
In 2017, the Arizona Department of Education (“ADE”) engaged Afton to support an assessment of the source of a 2014 audit finding regarding incorrect Title I LEA allocations, and to help identify solutions to prevent any recurrence of the errors identified in the audit. These misallocations were initially thought to be a $400K calculating error. After conducting an investigation, Afton found over $30M of Title I funds that were misallocated from 2014 to 2017, and developed a new allocation template and methodology for Title I funds.
To complete this work, Afton first reviewed all historical materials to identify root causes of errors identified in the audit. Afton then retroactively developed correct 2014 – 2017 Title I LEA allocations, including proper set asides to Administration and the School Improvement Fund. Afton then compared correct allocations to actual allocations, and assisted ADE in developing action plans to address misallocations. Finally, Afton supported the ADE in developing mechanisms to ensure these errors are resolved and will not recur, such as proper training, policies and procedures.
Recognizing that increased transparency is of utmost importance, the ADE requested that Afton complete its engagement with a plenary speech and breakout sessions at the annual MEGA conference for Title I administrators. The plenary speech provided an overview of the state’s corrected Title I allocation process for LEAs, a discussion on the misallocations and how it had been addressed, and transparency on plans moving forward. Further details and ample opportunity for Q&A were provided in morning and afternoon breakout sessions, including time for one-on-one meetings with individual LEAs.
The ADE has utilized Afton’s recommendations and detailed analyses as it negotiates with the U.S. Department of Education to resolve the previous miscalculations and correct the allocation process and procedures moving forward. You can find Afton’s work toward the bottom of the Arizona Department of Education’s Title I website (here) and read about how the ADE corrected the Title I funds allocation process here.
Our Insights
Title I LEA Allocations is a complicated process, and a combination of factors likely contributed to ADE’s situation. Practices that can prevent this moving forward include:
- Creating and maintaining proper policies and procedures: Ensure policies and procedures remain updated, and ask questions when policies and procedures are unclear
- Ensure process integrity: Adhere to policies and procedures once they are created; ensure proper checks and balances in the process (and improving policy where needed); ensure data integrity; and maintaining proper documentation
- Practice effective communications: raise issues for proper resolution; and build appropriate protocols and practices to communicate effectively, particularly cross-functionally/departmentally
More broadly, as it comes to SEA allocations of federal funds, Afton has generally found that there is limited understanding and/or transparency into these processes. Engaging LEAs in dialogue on how funds are allocated, requirements around allocations, and how they can support efficient and effective allocations (for example, through clean and timely data inputs) can lead to better, more effective allocation practices.