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Susan Montee Yellow Sheet

Report No. 2007-32
August 2007

Inadequate State Laws for Background Checks and Inadequate Certification Database Controls Leave Public School Students at Risk

State law for educator background checks is not sufficient to ensure the safety of the state's public school students. The Department of Elementary and Secondary Education (DESE) is responsible for ensuring background checks are conducted on applicants for educator certificates and for reviewing background check results. However, imprecise language in state law and the omission of other critical laws and policies have allowed some educator certificates to be issued to individuals who have a criminal background or have a history of committing other offenses. DESE and Information Technology Services Division (ITSD) management also need to take the necessary measures to develop documentation, implement controls and edits, and enhance the functionality of the teacher and substitute certification databases to fully ensure the integrity and reliability of educator certification data. We focused audit efforts on determining whether (1) educator background checks required by law are sufficient to identify individuals who have a criminal history or have other issues involving moral turpitude, (2) DESE officials have complied with applicable background check laws, and (3) DESE and ITSD officials have established adequate controls to ensure the integrity and reliability of educator certification data and information.

Background checks for educators are inadequate

State laws regarding background checks for Missouri's educators are not adequate to ensure students are in a safe environment. State law requires applicants for most school district positions to have both a criminal history background check and a Family Care Safety Registry (FCSR) background check performed prior to having contact with a student. However, due to the imprecise language in the law, DESE officials have not been requiring and school districts may not be performing FCSR background checks prior to employing educators and other school district personnel who have contact with students. (See page 11)


Educator backgrounds may place students at risk

State law does not require FCSR background checks for educators before they can obtain a certificate to teach. In addition, while state law intended the Child Abuse/Neglect Central Registry to be checked as part of the FCSR background checks, state law does not specifically require Central Registry background checks for educators. During our review, we found instances of certified educators who had a criminal background and/or a history of committing other offenses, such as child abuse or neglect. We found records in the FCSR and Central Registry for certified educators who had been actively teaching in the 2006-2007 school year as well as records for certified educators who had not been actively teaching. DESE officials had been aware of some of these cases, determined the educator was not a risk to students and cleared the background. However, DESE officials had not been aware of all of the cases we found because FCSR checks and periodic background checks have not been required. (See page 12)


Periodic background checks are not required

State law does not require any periodic reviews of educator backgrounds to determine whether new crimes or other offenses have been committed. Periodic background checks help to ensure an individual who previously had a cleared background has not committed some type of offense since the initial review. (See page 15)


Social security numbers are not validated

The teacher and substitute certification databases contain records having invalid social security numbers (SSN). As part of the educator certification process, DESE requests each applicant's SSN. However, SSNs are not validated against an appropriate form of identification nor are there any policies or procedures requiring validation. The Missouri Adaptive Enterprise Architecture states the SSN is a critical component in many state agency applications and is used in facilitating the transfer of information and matching data between different sources. Invalid SSNs compromise data integrity and do not allow DESE officials to ensure the integrity of background checks requiring SSN as the identifying key. (See page 17)


Clearance list needs to be documented

The State Board of Education allows DESE officials to clear certain types of adverse backgrounds without obtaining approval from the board. However, the State Board of Education has not adopted a policy to delegate the clearing of adverse backgrounds and a comprehensive list identifying the offenses DESE officials can clear has not been documented. Documenting the specific offenses that can be cleared provides assurance to the department and the public that cases are handled consistently and individuals with adverse backgrounds, including felonies or crimes involving moral turpitude, have not been certified. (See page 18)


Inappropriate substitute certificates have been issued

The substitute certification database processed and automatically issued certain certificates to applicants prior to the required clearance of criminal background checks during the 2006-2007 school year. A DESE official believed this issue could have been the result of a programming change made during the school year that was subsequently fixed within a short period of time. (See page 22)


A documented data dictionary is needed

A data dictionary has not been developed or documented for the teacher or substitute certification database applications. A data dictionary should enable the sharing of data elements among applications, promote a common understanding of data among users, and prevent incompatible data elements from being created. (See page 22)


Certification databases require improvement

DESE uses several databases and web applications to process and maintain criminal background check results, applications for educator certificates, certification history and applicant professional requirements; and to provide information to school districts on the status of applicant certificates. Many of these educator certification databases and applications are older systems, lacking in necessary controls such as audit trails, key edit checks, and functionality generally available with new technology. As a result, improvements are needed to ensure the accuracy, completeness, and reliability of educator certification data. (See page 23)


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Missouri State Auditor's Office