Financial audit of Boston Public Schools student activity accounts released

Mayor Martin J. Walsh today announced the findings of the independent audit conducted by Ernst & Young (EY) of student activity accounts at Boston Public Schools (BPS). The EY audit analyzed fund activity and use, assessed key internal controls and reviewed historical transactions at 118 schools in the BPS system, excluding the six Horace Mann Charter schools due to their autonomy, for School Years 2013 through 2018, or the past five years.

"Student activity accounts were launched in the early 1990s and, while they are in most of our schools in Boston, these accounts have never been audited or reviewed until now," Mayor Walsh said. "Trust, transparency and being fiscally responsible for the residents of Boston is what drives our priorities, and this in-depth review has allowed for the creation of substantial and comprehensive new policies and procedures. I want to thank our school leaders for their partnership in this review and for embracing these new guidelines as we begin the new school year."

EY was retained by the City of Boston following an audit by the Internal Revenue Service (IRS) that included a review of student activity accounts at 16 randomly chosen schools. Several operational changes were made at the City of Boston and BPS as a result of the IRS audit, including eliminating the use of local accounts, requiring all student activity funds to be held and managed through the City of Boston's financial system, enhancing controls and clearer communication to school leaders regarding the rules surrounding student activity accounts.

"The Boston School Committee is committed to implementing and upholding policies and practices to ensure all funds in the Boston Public Schools are safeguarded and being used appropriately," Boston School Committee Chairman Michael Loconto said. "We thank Mayor Walsh, BPS staff, and Ernst & Young for their continued cooperation and assessment of student activity accounts. The School Committee looks forward to reviewing the upcoming proposal to ensure stronger accounting practices in the district, and working with the Internal Audit Task Force that was approved by the Committee last winter to advance prudent fiscal oversight for our school system."

As EY's work was ongoing, the City of Boston and BPS took significant steps to address any potential risks uncovered by their review and ensure the proper policies and procedures were in place before the beginning of the school year. These actions are in addition to the changes already made in response to the IRS audit and include the following:

• Created a Superintendent Policy and a Student Activity Account Operating Manual that provides a comprehensive set of rules and procedures for student activity fund management;
• Drafted a policy that will be presented to the School Committee for approval in September that complies with all statutory and regulatory requirements for student activity accounts;
• Provided comprehensive training on the new rules and procedures to school leaders in August that will be held annually by BPS;
• Created a Master Agency Account that provides the necessary financial controls by requiring all student activity deposits and expenditures to be managed through the City of Boston's financial system; and,
• In addition to including the Master Agency Account as part of the City of Boston's annual financial auditing process, put in place a requirement for operational audits that will be conducted at schools on a rotating basis by BPS to ensure ongoing compliance with all policies.  

EY also identified several specific control and procedural gaps that presented the highest potential risk, including those related to segregation of funding sources, expenditures and duties, tax reporting process, appropriateness of fund usage, cash collection and on-hand cash procedures. Each of these priority issues have been addressed through the new policies and operating manual, the Master Agency Account that requires all expenditures to go through the City of Boston's payment system, the new internal auditing process that will be implemented at BPS, new guidelines on maintaining appropriate documentation on the sources of funds, a stated procedure for the handling and reconciliation of funds prior to and after deposit and the elimination of local accounts.

"The structures and protocols we have implemented as a result of the EY audit will ensure that, going forward, student activity accounts are used to empower educators to provide BPS students with opportunities for well-rounded and engaging educational experiences in a transparent and thoughtful manner," Interim Superintendent Laura Perille said. "BPS is grateful to all those who participated in and worked on this important initiative to maintain sound fiscal stewardship over these modest but important components of spending in our schools."

The proposed School Committee policy will be presented to the Boston School Committee for approval at their meeting on September 12, 2018. The Student Activity Operating Manual and Superintendent Policy was presented to school leaders at the August Leadership Institute and can be found here.

Student activities are broadly defined to be co-curricular in nature, contingent on a fee or on external fundraising and for the sole benefit of students. BPS recognizes the following as student activities:

• Socials, for instance a prom or student pizza party;
• Special events, for instance a graduation or a Science Fair;
• Field trips, for instance transportation costs or entry fees;
• Approved student clubs, for instance student council or debate club;
• Bookstores, only when the bookstore is run by students and proceeds will benefit students directly;
• Athletics, only when funds are student-driven or student-initiated and proceeds will benefit students directly; and,
• Certain miscellaneous, student-related activities.

EY spent three to five days at each school during their review and produced a summary of school specific findings in addition to their overall report. These school specific summaries are available online for further review by school leaders and the school community.