Internal auditors find gaps in district special-education documentation; recommend handbook, KPIs and training

Matt Blondell, director of internal audit for RSM, and audit team member Weiss Campbell presented results of the firm’s review of the district’s Exceptional Student Education (ESE) services and the firm’s proposed fiscal-year 2026 audit plan to the Lee County School Board on Aug. 5. RSM said the ESE review focused on regulatory compliance and the IEP (individualized education program) development and implementation process.

The audit team said it tested 40 IEPs and more than 400 services and accommodations and found three recurring exceptions: one IEP lacked documented parental participation or a parent-decline record; auditors could not substantiate the delivery of about 76% of the sampled services and accommodations; and 11 of 36 IEPs that required progress reporting had not uploaded those reports to the state tracking system. "We did identify 2 high risk observations," Campbell said during the presentation, adding that the district lacked consistent documentation and a unified oversight framework.

The audit team recommended steps to remediate those gaps. Management’s written response, discussed during the workshop, includes creation of a handbook that "outlines expectations and explicitly defines criteria relating to the most common services and accommodations that should be documented and how those actions should be documented," targeted staff training on roles and responsibilities, development of standard operating procedures and a unified organizational chart, quarterly sampling audits where resources permit, and development of KPIs to monitor performance.

RSM also reported results from its follow‑up testing across older audits: auditors said there were 38 original observations across eight prior reports, more than half of which have been closed, with 13 items in progress and five not yet ready for re‑testing. RSM proposed that follow‑up testing be reported quarterly going forward to improve accountability.

Looking ahead, RSM presented a proposed fiscal‑year 2026 audit plan focused on: a sensitive data protection (IT) project that will examine student information and ERP systems (PeopleSoft) for access controls, encryption and segregation of duties; a budgeting audit covering development, monitoring, reporting and budget modifications; a contract‑administration review of up to five high‑risk contracts to test vendor monitoring and invoice approval; and continued follow‑up testing on open audit items. "Follow‑up testing this year will be pretty significant," Blondell said, identifying 10 audits and 26 open observations that would be followed in FY26.

Board members asked for regular updates and for the district to return with concrete plans on ESE changes. Superintendent Denise Carlin said she has tapped executive staff to ensure management implements the audit recommendations and agreed to bring progress reports back to the board. "That’s who will be ultimately responsible for ensuring the completion of the actions provided for you," she said.

The audit presentation did not propose new policy changes for board approval; it recommended management actions and an audit schedule for the coming year. The board asked RSM to prepare a statement of work for the proposed FY26 audits and indicated it expects follow‑up updates in the fall.

Ending: RSM will convert the proposed FY26 plan into a formal statement of work for the board and said it will report on follow‑up testing on a quarterly basis to the audit committee and the board. The district pledged to return with progress reports that will show how the handbook, training and monitoring changes are being implemented.