Seattle Public Schools The Office of Internal Audit

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Seattle Public Schls The Office f Internal Audit Internal Audit Reprt September 1, 2013 thrugh August 31, 2016 Issue Date: June 13, 2017

Backgrund Infrmatin Executive Summary The District emplys apprximately 6,300 full time equivalent emplyees, the majrity f whm accrue leave time fr absences such as persnal, sick and vacatin. Bard Plicy N. 5400 gverns emplyee leave time and ensures cmpliance with the Revised Cde f Washingtn. Cllective bargaining agreements, management cmpensatin bulletins, and payrll administrative prcedures set frth the rules, regulatins, and prcedures related t accruing leave, and requesting and reprting the use f leave time. The District uses Emplyee Self Service (ESS) as its payrll system fr reprting emplyee time and attendance. ESS is an exceptin-based system, thus emplyees regular wrking hurs are pre-ppulated int the system. Emplyees nly need t access the system t reprt absences, which are cnsidered exceptins t their regular schedule. If there are n absences that need t be reprted, emplyees d nt need t lg int the system t recrd time wrked r t certify that their payrll is accurate. Unless emplyees lg in t ESS t recrd their absences, they are autmatically paid their regular wages with n reductin in their leave benefit balance. This applies t standard emplyees with regular schedules. Hurly emplyees must lg in t ESS t recrd their hurs wrked. In additin t ESS, the District has a substitute management system, Subfinder (replaced with Aesp n July 1, 2016). The substitute management system is used t request and dispatch substitutes t fill emplyee absences (sick, persnal, vacatin, etc.) r fr ther matters such as prfessinal develpment wrkshps. Only emplyees in substitutable psitins such as teachers, paraprfessinals, and clerical staff use this system. ESS and the substitute management systems are separate systems with different functins, and the systems are nt integrated. Therefre, if a substitutable emplyee needs a substitute t fill-in fr their absence, the emplyee must recrd the request fr a substitute in the substitute management system and recrd their actual absence in ESS. If n substitute is needed an emplyee is nly required t reprt the absence in ESS. Schls and sme departments at central ffices have timekeepers t mnitr time reprting; hwever, emplyees are ultimately respnsible fr their wn leave time. Emplyees are respnsible fr recrding all absences, and managers are respnsible fr ensuring that emplyees are accurately recrding absences t ensure accurate time accunting and payrll prcessing. District management was alerted t pssible absence variances between ESS and Subfinder that may have resulted in unrecrded leave time fr substitutable emplyees. An initial analysis f emplyee leave time cnducted by District management cnfirmed the discrepancies between absences recrded in Subfinder and ESS, as well as cncerns regarding ptential unrecrded leave fr central administratin staff. This infrmatin prmpted management t request an internal audit f emplyee leave time fr substitutable emplyees and fr nn-represented management staff and schl administratrs. This audit will als highlight thse areas where emplyees may nt have clear guidance n the prcedures they are expected t perfrm, and it will identify thse situatins where they have nt been prvided adequate resurces t perfrm these key functins prperly. 2 f 17

Rles and Respnsibilities This audit was cmpleted as part f the amended Annual Risk Assessment and Audit Plan apprved by the Audit and Finance Cmmittee n December 13, 2016. District management became aware f cncerns related t emplyee leave time, and upn cnducting an initial review determined the cncerns culd be significant and requested Internal Audit services t ensure a thrugh and bjective review. District management has the primary respnsibility t establish, implement, and mnitr internal cntrls. Internal Audit s functin is t assess and test thse cntrls in rder t prvide reasnable assurance that the cntrls are adequate and perating effectively. We cnducted the audit using due prfessinal care, and we believe that the evidence btained prvides a reasnable basis fr ur findings and cnclusins. Audit Objectives and Scpe The bjectives f this audit were t determine if: Emplyee absences were prperly recrded in the District s time and attendance system fr the fllwing emplyee grups: Emplyees Using Subfinder, including Certificated Nn-Supervisry Emplyees, Paraprfessinal Staff, and SAEOP (Seattle Assciatin f Educatin Office Persnnel) fr the perid f September 1, 2014 thrugh August 31, 2016. Nn-represented management emplyees and PASS emplyees (Principals Assciatin f Seattle Schls) fr the perid f September 1, 2013 thrugh August 31, 2016. The District has implemented adequate internal cntrls ver emplyee leave time t ensure accurate reprting and cmpliance with the District s plicies and prcedures. Audit Apprach and Methdlgy T achieve the audit bjectives, we perfrmed the fllwing prcedures: Planned the audit in cperatin with staff frm the Business and Finance, Human Resurces, and Payrll departments t ensure that we had a strng understanding f the District s leave time prcess. Interviewed staff knwledgeable f the varius prcesses cvered during the curse f the audit. Reviewed applicable District plicies and prcedures, cllective bargaining agreements, and management cmpensatin bulletins fr cmpliance requirements. 3 f 17

Wrked with staff frm the Departments f Technlgy Services, Human Resurces, and Payrll t btain accurate and reliable data. Cnducted a detailed analysis f available data t identify ptential unrecrded absences. Perfrmed tests and analysis f the bjective areas t supprt ur cnclusins. A detailed descriptin f the audit apprach and methdlgy is in the Appendix f this reprt. Cnclusin Based n the results f the audit prcedures perfrmed, we cnfirmed that there are unrecrded emplyee absences that warrant the District s attentin, and that the District des nt have adequate cntrls ver leave time reprting t ensure cmpliance with its plicies and prcedures. This reprt identifies recmmendatins that are intended t imprve the verall accuntability and transparency f leave time reprting. We extend ur appreciatin t the staff within Business and Finance, Human Resurces, Payrll, the Department f Technlgy Services, and staff acrss schl lcatins and central ffices fr their assistance and cperatin during the curse f the audit. Andrew Medina Andrew Medina, CPA, CFE, LPEC Directr, Office f Internal Audit 4 f 17

Findings and Recmmendatins 1) Unrecrded Absences fr Emplyees Using Subfinder Emplyees, such as teachers, paraprfessinals, and ffice staff can request a substitute fr absences such as vacatin, sick leave, and persnal days. During the 2014-2015 and 2015-2016 schl years, these emplyees wuld request a substitute thrugh the District s Subfinder system. The Subfinder system recrded the dates that a substitute was needed, and the type f absence causing the need fr a substitute. Hwever, the Subfinder system was nt the fficial leave timekeeping system fr the District, and emplyees are required t recrd all absences in Emplyee Self Service (ESS), which is the District s fficial timekeeping system. On July 1, 2016, the District replaced Subfinder with a new substitute management system, Aesp. The new system has primarily the same functinality as the previus system in regards t leave time reprting, and des nt interface with ESS. We cnducted a cmparisn f absences recrded in Subfinder with absences recrded in ESS t determine if all absences were prperly recrded. Our analysis was based n the ttal absence days fr a full year and was specific t Subfinder absences recrded as either sick, persnal, r vacatin days. We excluded absences such as leaves f absence, jury duty, and bereavement leave. Leaves f absence are recrded by the Human Resurces Department and appear t have adequate cntrls. Other leaves such as jury duty and bereavement leave d nt impact emplyee leave balances and are deemed less risky. The results f ur analysis revealed the fllwing variances: Fr the 2014-2015 schl year, 1,353 emplyees recrded mre absences in Subfinder than in ESS. The amunt f absences that were nt recrded in ESS ttaled 2,911 days (equivalent t 22,334 hurs). Of these emplyees, 74 recrded zer absences in ESS. Fr the 2015-2016 schl year, 1,464 emplyees recrded mre absences in Subfinder than in ESS. The amunt f absences that were nt recrded in ESS ttaled 3,364 days (equivalent t 25,498 hurs). Of these emplyees, 68 reprted zer absences in ESS. The results f ur data analysis als revealed the fllwing infrmatin relevant t the abve variances: A ttal f 560 emplyees had unrecrded variances in bth years which ttaled 2,765 days (equivalent t 21,152 hurs), which is 44% f the ttal variance ver the tw-year perid. Discrepancies in absence reprting were nted in all three persnnel areas: 65% certificated nn-supervisry staff, 28% paraprfessinal staff, and 7% ffice persnnel. Nearly all schls had unrecrded variances, hwever, seven schls cnsistently had the highest variance. These schls had a discrepancy f 731 days r 25% f the 2014-15 schl year variance, and 952 days r 28% f the 2015-16 schl year variance. 5 f 17

If emplyee leave balances were adjusted t crrect the unrecrded absences, 423 emplyees will have a negative leave balance, ttaling a negative 11,375 hurs. There were 76 emplyees that cashed ut 38,354 hurs f leave time fr a ttal f $405,803. These emplyees had 1,133 hurs f unrecrded absences, and 38 f them are still emplyed by the District. Of these 76 emplyees, 54 wuld have a negative leave balance if their balances were adjusted t crrect the unrecrded absences. The negative leave balance fr these emplyees wuld ttal a negative 845 hurs. Seventeen f these emplyees are still emplyed by the District. T cnfirm the reliability and accuracy f the analysis results, we perfrmed further review f the variances fr 40 emplyees. Based n the wrk perfrmed, we learned that since ur analysis is based n the ttal absence days fr a full year, it is pssible fr sme emplyees t have lgical explanatins fr their variances. Exact variances can nly be determined by cnducting a detailed evaluatin f emplyee recrds n a daily basis and evaluating the circumstances fr each emplyee. Fr these reasns, it is als difficult t quantify the verall financial impact t the District. The financial impact depends n whether the emplyees used their inflated leave balances t take leave r if they chse t cash it ut. Each emplyees rate f pay, and the rate f pay f the substitute emplyees, als impact the financial calculatin. As a result, we have nt calculated the financial impact t the District. Recmmendatin We recmmend that the District take steps t adjust emplyee leave balances fr absences that were nt recrded in ESS. We suggest that letters be sent t emplyees infrming them that their leave balance will be adjusted unless they can prvide adequate dcumentatin by a specific date. Management shuld wrk with the cllective bargaining grups prir t finalizing the letters. The letters shuld include the fllwing infrmatin: Details f emplyee s unrecrded variances and ttal leave that will be adjusted. Deadline by which the emplyee must prvide supprting dcumentatin t demnstrate that their leave balance is crrect and des nt require adjusting. Cntact infrmatin fr emplyees t prvide dcumentatin and ask questins. Appeals prcess an emplyee can fllw if they disagree with the determinatin made after submitting their supprting dcumentatin. 6 f 17

2) Unrecrded Absences fr PASS and Nn-Represented Management Staff Unlike emplyees that use a substitute management system, PASS (Principals Assciatin f Seattle Schls) emplyees and nn-represented management staff nly recrd absences in Emplyee Self Service (ESS). Since they cannt request a substitute t cver their absences, there is n secndary system dcumenting their absences. We analyzed ESS data frm September 1, 2013 t August 31, 2016 t identify emplyees that may have under-recrded their absences. Specifically, we analyzed data fr emplyees that recrded zer, r very few absences. The results f this analysis revealed that: The District emplyed 857 PASS and nn-represented management emplyees during this time perid. These emplyees recrded an average f 23 absence days per year. A ttal f 159 emplyees had at least ne year where they recrded less than three days f absences. Of these emplyees, 87 had at least ne year where they recrded zer absences. A ttal f 48 emplyees recrded less than three absences fr tw r mre years. We examined the 48 emplyees wh recrded less than three absences fr tw r mre years and determined that there was a lgical reasn why there were n absences r very few absences reprted fr 34 emplyees. We cnsidered start and end dates f emplyment, leaves f absences, changes in emplyee psitin (e.g. teacher t principal), changes in type f emplyment (e.g. casual hurly t regular salary), and the number f days the emplyee was cntracted t wrk. The remaining 14 emplyees with less than three absences fr tw r mre years will require additinal analysis t determine if the emplyee has unrecrded absences. Included in this analysis are six emplyees wh had tw r mre years where they recrded zer absences. We selected these six individuals fr further review and interviewed the managers wh supervised these emplyees. Interviews with the managers revealed the fllwing: Tw emplyees had n leave, due t limited staff in their department and time sensitive prjects that made it difficult t take time ff. Tw emplyees n lnger wrk fr the District. One emplyee was knwn fr nt missing any days f wrk. The manager fr the secnd emplyee n lnger wrks fr the District. Tw emplyees were recalled t have taken leave and the mangers agreed t cnduct additinal prcedures t determine if the emplyees had unrecrded absences. We als nted that a ttal f 463 emplyees cashed ut leave ttaling $3.97 millin. Furteen f these emplyees, nine f which are still emplyed by the District, recrded less than three days f absences fr tw r mre years and cashed ut 5,983 hurs f leave fr a ttal f $173,086. Cashut amunts fr these 14 emplyees ranged frm $547 t $35,892. 7 f 17

Recmmendatin We recmmend that the District determine if leave balances shuld be adjusted fr the 14 emplyees requiring additinal analysis that recrded less than three days f absences fr tw r mre years. The District shuld wrk with the emplyees and their direct supervisrs, and review emplyee calendars, emails, and ther supprting dcumentatin t determine if the emplyees have unrecrded absences. Any unrecrded absences detected shuld be adjusted accrdingly. The District shuld als determine if the unrecrded absences impacted any emplyee cash uts and seek reimbursement if applicable. 8 f 17

3) Internal Cntrl Weaknesses Over Internal Cntrls Over Absence Mnitring and Apprval Prcess We met with key persnnel invlved in the mnitring and apprval f absence reprting acrss varius schls and departments. We identified the fllwing weaknesses that may have cntributed t discrepancies in leave time reprting: Many principals and managers rely heavily n a timekeeper t ensure the accuracy f absence reprting; hwever, the timekeepers have nt received adequate guidance and training t ensure they are mnitring absences apprpriately. The training, resurces, and guidance prvided t timekeepers, principals, and supervisrs des nt cntain enugh detail t illustrate the necessary steps required t ensure accurate absence reprting. The current level f training prvided is cnsidered vague by timekeepers and ften leaves attendees with unanswered questins and withut specific examples f the steps they shuld be taking t verify accurate leave time recrding. The prcedures and level f detail cnducted t mnitr absence reprting varies acrss schls and departments. There are n standard exceptin reprts r recnciliatin prcedures that must be perfrmed n a regular basis. The frequency that schl timekeepers perfrmed a recnciliatin between the substitute management system and ESS varies frm weekly t every three mnths, and sme schls nly spt-checked absence reprting every s ften. There are n clear expectatins fr timekeepers t fllw in regards t hw ften they must perfrm a recnciliatin. When staff fail t reprt absences in ESS timely, timekeepers ften send reminders t staff, but there are incnsistencies in the level f fllw-up prcedures perfrmed by the timekeepers. Sme timekeepers stp after they send a reminder withut perfrming additinal recnciliatin prcedures. Other timekeepers will input absences n an emplyee s behalf if the emplyee fails t recrd their wn leave. Timekeepers lack guidance n hw they shuld prceed when they identify unrecrded absences and what degree f authrity they have t crrect an emplyee s leave recrding. Administrative prcedures related t absence reprting are nt easy t find n the intranet and are nt shared with emplyees regularly t remind them f their leave time recrding respnsibilities. In additin, timekeeping is nly briefly cvered in new emplyee nbarding. This lack f attentin des nt demnstrate a strng tne at the tp regarding the imprtance and accuntability f accurate leave time recrding. The fllwing circumstances can increase the likelihd f unrecrded absences because the managers d nt always have firsthand knwledge f emplyee leave time: Decentralized reprting structures, where supervisrs must mnitr leave time fr emplyees assigned t different building lcatins. 9 f 17

Supervisrs with a large number f staff that reprt directly t them. Emplyees whse direct supervisr is nt respnsible fr their leave time apprval. Departments may be structured with multiple levels f supervisin, but leave time apprval is assigned t the department directr. There is unclear guidance regarding cmpensatry time (time ff in lieu f pay) as well as flexible time (alternate wrk schedules). Many District emplyees wrk in excess f 40 hurs per week; hwever, there is limited guidance advising emplyees n when they can make up an absence instead f using leave time, r what type f dcumentatin and apprval are required when an emplyee will be making up time. Internal Cntrls Over the Substitute Management System and Emplyee Self Service During the curse f ur audit, we nted the fllwing cncerns in the District s substitute management system and timekeeping system. Having tw separate systems t recrd absences that are nt integrated increases the likelihd f discrepancies in absence reprting. The District s exceptin based payrll system des nt require standard emplyees t enter their time wrked, r t certify the accuracy f their time and attendance reprting. Unless emplyees lg in t ESS t recrd their absences, they are autmatically paid their regular wages with n reductin in their leave benefit balance. Since emplyees will cntinue t be paid if they fail t lg in t ESS, it increases the likelihd f unrecrded absences. Emplyees cannt access ESS unless they are signed int the District s netwrk, which increases the likelihd that they will frget t recrd their absences upn returning t wrk. In additin, since emplyees d nt regularly access ESS they may nt remember t input absences. Incrrect persnnel numbers were used in Subfinder. We fund persnnel numbers reprted in Subfinder that did nt exist in ESS r were fr entirely different emplyees. Attendance fr prfessinal develpment wrkshps were miscded as sick r persnal leave in Subfinder. Emplyees are unable t request a substitute in the substitute management system fr prfessinal develpment wrkshps. Only the designated timekeeper r Human Resurces Department can request a substitute fr prfessinal develpment leave. Rather than wait fr the timekeeper r Human Resurces t request a substitute t cver prfessinal develpment leave, an emplyee may intentinally recrd the leave as either sick leave r persnal leave in the substitute management system in rder t ensure that a substitute will be available t cver their class. Substitutes were requested fr emplyees that n lnger wrked fr the District. This ccurred when the schl needed a substitute t fill absences created by vacant psitins. 10 f 17

Absences were reprted in the substitute management system fr emplyees that did nt require a substitute t fill the vacancy. The system has the ptin t select whether a substitute is required r nt required. There is incnsistent infrmatin abut when the substitute management system shuld be used. Sme emplyees are infrmed t recrd all absences in the substitute management system, and sme nly use it when a substitute is required. Emplyees were able t request mre than 1.0-day absence fr ne full day in Subfinder. We learned this was addressed with the implementatin f the new Aesp system as it limits the maximum number f hurs t 8.5 hurs fr any given day. The impact due t discrepancies in time and attendance reprting is nt nly limited t Seattle Public Schls. There are instances in which emplyees have the ptin t retain and transfer their leave benefit balance when resigning frm the District and becming emplyed at anther schl district in the state f Washingtn. The risks are then passed n t the new district and ultimately public resurces are at risk f ver-payment. Recmmendatin We recmmend that the District: Establish a strng tne at the tp message regarding accurate leave time recrding, and increase the awareness f the requirements assciated with recrding absences. Management plays a critical rle in setting the tne fr staff, and a cnvincing message regarding management s cmmitment t accuntability can increase emplyee cmpliance. Imprve the training, guidance, and resurces prvided t timekeepers, principals, and managers t ensure cnsistent and accurate recrding f emplyee absences. Specifically, the guidance shuld be easily accessible and shuld include: Which reprts shuld be generated in rder t cmplete a recnciliatin between ESS and the substitute management system. Hw ften the recnciliatin needs t be perfrmed. What fllw-up prcedures shuld be cnducted when variances are nted. What authrity timekeepers and supervisrs have t ensure the prper recrding f emplyee leave balance, including whether r nt timekeepers can input leave n behalf f emplyees. Imprve the guidance related t cmpensatry time and flexible time t ensure that emplyees understand when they must recrd an absence in ESS. 11 f 17

Review the number f emplyees assigned t each manager t ensure that managers can reasnably mnitr emplyee absences. In additin, review the assignment f the absence apprval rle in ESS t ensure that managers that have direct knwledge f emplyees wrk and attendance are assigned t apprve emplyees absences. Require emplyees t certify in ESS each pay perid that their recrded leave time is accurate. Implement prcedures t hld emplyees and supervisrs accuntable fr prper leave time reprting. Explre integrating the District s substitute management system and ESS systems t ensure prper leave recrding as well as imprve efficiency. In cmbinatin with strengthening internal cntrls, this shuld increase the accuracy f time and attendance reprting, reduce ptential verpayments, and reduce time and resurces spent t recncile the tw systems. Until the substitute management system and ESS are integrated, implement additinal mnitring cntrls t assist in identifying instances f unrecrded leave n a timely basis, and t assist in recnciling the time and attendance system with the substitute management system. A peridic review f exceptin-based absence reprts fr all emplyees, including substitutable emplyees, PASS, and nn-represented management shuld be perfrmed. Ensure nly valid persnnel numbers are used in the substitute management system. Strengthen its cntrls t ensure crrect absence cdes are used in the substitute management system and ESS. Explre ways t better track prfessinal develpment withut impacting emplyee leave balances and cnsider allwing emplyees the ability t recrd their wn prfessinal develpment in the substitute management system. Ensure terminated emplyees are prmptly remved frm bth systems and recrd the psitin that requires a substitute as a vacancy in the substitute management system rather than have it tied t a terminated emplyees persnnel number. Clarify when the substitute management system must be used. Specifically, infrm emplyees if it shuld be used t recrd all absences r nly absences when a substitute is required t fill a psitin. 12 f 17

Management Respnse We cncur with the findings utlined in this reprt. As nted in the reprt, this wrk was dne at the request f District management. A thrugh review f reprted absences is currently underway. It is ur belief there are system imprvements that will require technlgy slutins. We will be wrking with ur Department f Technlgy Services t utline and determine system imprvements and next steps. 13 f 17

Appendix: Audit Apprach and Methdlgy Our analysis f unrecrded leave is based upn a large amunt f emplyee data analyzed ver a multi-year perid. The fllwing infrmatin summarizes the prcedures we perfrmed in rder t cmplete the analysis and discusses sme f the challenges assciated with the analysis: During ur analysis, we fund certain limitatins f the data that prevent us frm reprting exact figures. As a result, there culd be mre r less discrepancies than ur reprt indicates. Further infrmatin f ur apprach and methdlgy are detailed belw: 1.) Substitutable Staff (Teachers, Paraprfessinals, Office Persnnel) i. We analyzed tw years f relevant data, during September 1, 2014 thrugh August 31, 2016 t identify unreprted absences in the District s time and attendance system. We cmpared absence data frm the substitute management system and the time and attendance system. The expectatin is that when an emplyee in a substitutable psitin will be absent frm his/her psitin, the emplyee r Substitute Office will dcument the reasn fr the absence in the substitute management system and request a substitute t fill the absence. In additin, the emplyee must als recrd the absence in the time and attendance system t reflect actual time wrked. ii. iii. We fcused ur analysis n sick, persnal, and vacatin leave and did nt include ther absence types reprted in Subfinder. Apprximately, 74% f absences were cded as sick r persnal leave, 23% as leaves f absence, and 3% as bereavement r jury duty. We excluded Subfinder absences cded as leave f absence frm ur analysis as these types f absences are prcessed differently frm ther types f absences. See further explanatin under paragraph iv belw. We determined the likelihd f misreprting bereavement, jury duty, and leaves f absences was a lwer risk. The type and level f detail in absence data reprted in bth systems are nt the same; therefre, we used ur best judgment t analyze the data. a. The difference in reprting between the systems cntributes t sme emplyees shwing greater amunt f absences reprted in ESS cmpared t the substitute management system. ESS shws the actual number f hurs and days per absence reprted. The Subfinder system nly shws absences in half r full days. An emplyee may actually reprt less than a half-day absence in ESS, but still reprt a full day absence in Subfinder. In additin, we nted instances when an absence may be reprted in ESS; hwever, n substitute was requested in Subfinder. b. The absence cdes used in Subfinder cmpared t ESS are nt the same. Subfinder has six absence cdes cmpared t twenty-ne (21) cdes fr ESS. Therefre, an absence may be reprted as ne type such as Sick Leave in Subfinder and be reprted as a different absence type in ESS such as injury n duty. 14 f 17

1.) Substitutable Staff (Teachers, Paraprfessinals, Office Persnnel) Cntinued i. Absence cdes in Subfinder include: Sick, persnal, vacatin, military, bereavement, jury duty, and leave f absence. ii. Absence cdes in ESS include: Sick, persnal, vacatin, vacatin during break, adptin, bereavement, jury duty, snw/inclement weather, n leave available, emergency leave, injury n duty paid, injury n duty unpaid, IOD medical treatment, military leave, sub sick leave, religius leave - unpaid, unpaid leave, unpaid sick, shared leave, unpaid child care, and unpaid child bearing. c. Fr each emplyee, we summed the aggregate amunt f sick, persnal, and vacatin absence days reprted in Subfinder and cmpared this t the aggregate amunt f absence days we believed reasnably culd have been used in ESS. Thus, we included all absence cdes nted in the preceding paragraph, with the exclusin f adptin, n vacatin during break, n leave available, r snw/inclement weather as we fund emplyees included in ur analysis did nt have these types f absences reprted in ESS. d. Althugh we excluded absences cded as leave f absence within Subfinder frm ur analysis, we did nt have a reasnable methd t distinguish which absences in ESS are actually related t thse leaves f absences. Thus, ur analysis is likely giving mre credit t sme emplyees absences reprted. As an example, an emplyee may have five sick leave days and 10 leave f absence days reprted in Subfinder, thse absences culd be reprted as any given paid r unpaid cde in ESS such as unpaid leave, unpaid sick, etc. iv. Excluding all leaves f absences frm Subfinder data limited ur analysis t thse emplyees that truly appeared t have under-reprted absences in ESS. When emplyees are inactive and in unpaid status, they are n lnger cnsidered active in the District s accunting system. This shuts dwn thse emplyees, which prevents them frm being paid r earning benefits. N absences are inputted int ESS at this pint. This actin is perfrmed by Human Resurces. If we include leave f absences in ur analysis, it wuld result in a significant discrepancy in ur analysis as Subfinder may shw leave f absence reprted, hwever, fr many emplyees there will be n absences reprted in ESS. v. We estimated emplyee leave benefit balances after taking int accunt the unreprted absences that shuld have reduced the leave balances. We cnverted the ttal number f unreprted absence days int hurs based n emplyees FTE and the amunt f regular wrking hurs per day, which is based n an 8-hur r 7-hur day depending n the emplyees psitin type. We assigned 8-hur days fr teachers and ffice persnnel and 7-hur days fr paraprfessinals. 15 f 17

vi. The Payrll Department prvided emplyee leave benefit balances as f December 2, 2016 and cash ut data as f August 31, 2016. Exact adjustments t balances will vary depending n leave used, accrued amunts, and leave cash uts made since then. vii. T cnfirm the reliability and accuracy f the results f ur analysis, we selected 40 emplyees frm ur analysis that appeared t have unreprted absences fr further testing. We judgmentally selected emplyees fr further testing that appeared t be higher risk including emplyees with large amunt f variance in unrecrded absences, emplyees that had zer absences reprted in ESS, emplyees with large estimated negative leave balances, and emplyees with leave cash uts. We cmpared line by line, the exact dates that absences were reprted in bth systems. viii. Our analysis prvides a starting pint fr identifying emplyees that may have discrepancies in absence reprting due t the aggregate apprach we used in estimating ttal absences and the limitatins f data we have nted abve. Hwever, there are likely t be variances between the results f the analysis and the emplyee s actual unrecrded absences, which culd nly be determined by cnducting a detailed evaluatin f each emplyee s recrds. 2.) Nn-represented Management and PASS Staff i. We analyzed three years f relevant data, September 1, 2013 thrugh August 31, 2016 t identify unrecrded absences in the District s time and attendance system. ii. iii. iv. We evaluated the data t determine whether there may be a reasnable explanatin fr why there were n absences reprted such as leaves f absences. Fr example, when emplyees are in inactive/unpaid status absences are n lnger reprted in the system. We als tk int cnsideratin emplyee start/end dates and changes in persnnel type. Fr example, an emplyee may start emplyment as a regular management and later change t a casual hurly emplyee that d nt earn r use leave. We determined whether emplyees had less than 3 days f absences recrded in ESS per year. Of thse emplyees, we nted which had tw r mre years f n absences recrded during the 3-year perid. We judgmentally selected emplyees that had multiple years f n absences reprted fr further review. After eliminating emplyees that appeared t have lgical explanatins fr n absences reprted, we identified six emplyees (2 principals, 4 management) that had tw r mre years f n absences reprted t evaluate further. T cnfirm the reliability and accuracy f the results f the analysis, we tested 48 emplyees frm ur analysis that had less than 3 days f absences per year, fr multiple years, including the 6 emplyees with n absences reprted fr multiple years. We cmpared the ttal amunt f absences frm the analysis t what was recrded in ESS. v. We met with the six selected emplyees direct supervisrs t determine whether it was reasnable fr emplyees t have n absences reprted during a schl year and t gain an understanding f hw supervisrs mnitr leave time. 16 f 17

vi. Our analysis prvides a starting pint fr identifying emplyees that may ptentially have discrepancies in absence reprting as indicated by unusually lw amunt f absences reprted. Hwever, determining whether an emplyee actual has unrecrded absences culd nly be determined by cnducting a detailed evaluatin f each emplyee s recrds. 17 f 17