DEPARTMENT OF EDUCATION

OFFICE OF THE INSPECTOR GENERAL

Florida Department of Education
Office of Inspector General

Audit of the Florida Inventory of School Houses

Final Report

Audit Number
06/07 – 06 A

March 14, 2008
Background
This audit was identified in the Office of Inspector General’s annual risk assessment and included in the approved annual audit plan.  It was performed in support of the Department of Education’s (DOE) goal of quality efficient services, as well as the strategic imperative to align financial resources with performance.
The Florida Inventory of School Houses (FISH) is the electronic database created and supported by the Office of Educational Facilities (OEF) to provide record keeping capabilities for all districts’ facilities.  The recorded data elements encompass a wide range of information --  school spaces are recorded by facility, parcel, building, and room number; design use; square footage; floor covering; exterior wall covering; owned or rented; year constructed, etc.
For Fiscal Year 2007-08, the districts were appropriated $209,272,040 for maintenance, repair, renovation, and remodeling.  Districts’ maintenance funds are allocated based on the square footage of their physical facilities recorded in the FISH.  The districts are responsible for their data entry, accuracy, and maintenance.
Section 1013.31(1)(b)1, Florida Statutes, mandates “the department shall annually conduct an onsite review of 5 percent of the facilities reported for each school district completing a new survey that year.  If the department's review finds the data reported by a district is less than 95 percent accurate, within 1 year from the time of notification by the department the district must submit revised reports correcting its data. If a district fails to correct its reports, the commissioner may direct that future fixed capital outlay funds be withheld until such time as the district has corrected its reports so that they are not less than 95 percent accurate.”  The OEF has interpreted the statutory language as five percent of a district’s net square footage (NSF) per FISH.  OEF selects enough schools to meet or exceed five percent.  OEF randomly selects schools and attempts to have at least one from each type (elementary, middle, and high school) and to also have an old, a middle-aged, and a newer school included in their onsite reviews.  All spaces in a selected school are measured and compared to the FISH.  Although there are ten statutory requirements for OEF to validate, districts pass or fail based on the square footage inventory.
Two assumptions where made in our work and in this report: 1) Variances less than five percent (positive or negative) were considered immaterial; variances greater than five percent (positive or negative) were considered reportable.  Positive variances indicate the measured space square footage exceeded the FISH-recorded square footage; and conversely, negative variances indicate the measured space square footage was less than the FISH recorded square footage.  2) There are two methods of determining a total variance: a) the absolute value in which all variance amounts are summed regardless of positive or negative sign, and b) all variance amounts, both positive and negative, are summed and tend to offset each other (the method we used which produces a more conservative variance).  Further background and finding detail are found in the appendices following the report findings. 
Scope and Objectives
The objectives of this audit were to: 1) determine the accuracy of the FISH; 2) determine how OEF authenticates the accuracy of the reported inventory (square footage, number of classrooms, other measurable units reported); and 3) evaluate internal controls over the above.  The scope of the audit included the current data contained in the FISH.  Districts are able to amend their records at any time.  Live district FISH data was exported to spreadsheets in late May or early July just prior to our fieldwork procedures.
Methodology
To achieve the objectives, the audit team: 1) researched and reviewed applicable statutes, rules, manuals, procedures, related reports, and supporting documentation; 2) interviewed appropriate staff; 3) tested a sample of FISH records against actual physical spaces; 4) reviewed OEF validation documentation; and 5) evaluated internal controls.
Standards
This audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing, published by the Institute of Internal Auditors.
Audit Results
Based on our testing of three districts, we noted:  1) The accuracy of the FISH square footage inventory can not be assured to meet the statutory 95 percent accurate requirements as illustrated by both the significant numbers of variances as well as the size of the variances.  2) Districts are not complying with the FISH Manual for facilities’ inventory.  3) The Department’s validation procedures warrant improvement.
Each finding is organized into these six segments:
•	Condition – The factual evidence found in the course of the audit.
•	Criteria – The standards, measures, or expectations used in making an evaluation and/or verification.
•	Cause – The reason for the difference between the expected and actual conditions.
•	Effect – The risk or exposure due to the condition being inconsistent with the criteria (the impact of the finding).
•	Recommendation – Suggested corrective action.
•	Management Response – Auditee opinion and statements regarding concurrence or non-concurrence with the finding and corrective action planned by management.

Finding 1 – The accuracy of the FISH square footage inventory in the districts tested can not be assured to meet the statutory requirements.

Condition:	Variances (the difference between the square footage of spaces measured and the FISH amount) were computed by quantity and by size.  We considered all variances above five percent reportable, and those above fifteen percent significant.  By quantity, our testing found 389 out of all 1,186 (32.8%) tested spaces had reportable variances.  Reviewing individual school quantities, twenty of the thirty (66.7%) schools tested had reportable variances, and fourteen of the thirty (46.7%) schools had significant variances.  Only three of the thirty (10%) schools had both immaterial (five percent or less) quantity and size variances.  Validation compliance did not translate into fewer variances.  As the table below illustrates, Leon had the greatest percentage of reportable variances for the spaces tested, and its schools had the widest range of variances.

District	
Percentage of All Spaces Tested With Variances Exceeding 5%	
The Range of Individual Schools With Percentage of Variances Exceeding 5%	

Brevard	
28.4	
11.4 - 51.8	

Leon	
37.4	
13.8 – 75.0	

Seminole	
32.7	
15.8 – 65.6	

While the quantity of variances is of concern, the size of the variances is much more indicative of problem areas.  Total square footage variances are the determinant of school and district accuracy.  Large variances occurred in large spaces and more large spaces are located in secondary schools (middle and high).  Validation failure (less than 95 percent accurate) primarily is due to variances in large spaces since variances in smaller spaces (especially classrooms) are commonly offset by variances in other small spaces.  The larger space variances were usually singular (schools usually have one gym, auditorium, dining area, and library) and additive (e.g., Covered Walkway space was often under-recorded or unrecorded).  The largest Covered Walkway space tested at an elementary school was less than 40,000 NSF compared to the largest at a high school which was over 157,000 NSF.  Most schools have Covered Walkway, Food Service (kitchen & dining areas), Inside Circulation (hallways), and Library spaces, but high schools have additional large spaces such as Auditorium; P E (Senior High Gym & Locker Rooms); and Medium and Large Industrial, Health, Technical, Vocational, and Business Lab spaces.
Comparing all square footage tested to the FISH, the FISH was understated by 62,683 square feet (SF) or 2.3 percent of the total FISH NSF.  However, this statistic is misleading as we noted a significant error in nine Mechanical Room spaces recorded for a high school.  Almost three acres (127,367 SF) of space was improperly recorded in the FISH.  With this error corrected, the FISH understatement was 190,050 SF or 7.4 percent.  The understatement is equivalent in size to almost three elementary schools, or two middle schools, or a small high school.  Further detail is provided in Appendix B.	
Criteria:	Section 1013.31(1)(b)1, Florida Statutes, states in part, “If the department's review finds the data reported by a district is less than 95 percent accurate, within 1 year from the time of notification by the department the district must submit revised reports correcting its data.”  	
Cause:	Districts’ did not ensure the accuracy of information used and calculations made.  Districts’ lack of focus on recording all square footage which can maximize maintenance funding.  The Department lacks effective enforcement mechanisms to ensure that districts’ inventory is accurate.	
Effect:	Inaccurately recorded inventory results in funding inequities among the districts.  For example, based on the data tested and the average amount appropriated per square foot (FY 07/08, $0.537), Brevard received excess funding of $100,908, Leon received excess funding of $10,185, and Seminole was underfunded by $124,384.	
Recommendation:	The Office of Educational Facilities should:
•	Emphasize to the districts the magnitude of errors noted in this audit and the funding which may be lost due to FISH inaccuracy.
•	Consider seeking legislative assistance for improved statutory enforcement capabilities for OEF to ensure FISH accuracy.
•	Amend validation procedures to focus testing more on large spaces and more schools.
•	Develop statistically valid sampling methods to project district-wide variances and potential funding errors based on testing.
•	Target areas which are more likely to have significant variances by focusing on the following:
•	Schools with little or no Covered Walkway and/or Inside Circulation space recorded in the FISH and schools with a lopsided ratio of Covered Walkway to Inside Circulation.
•	Large spaces, open classroom designs, and relocatables (100 percent).
	
Management
Response:	Finding 1, Recommendation 1: Emphasize to the districts the magnitude of errors noted in this audit and the funding which may be lost due to FISH inaccuracy.

OEF currently sends an annual notice to districts that requires superintendents and board chairs to certify the accuracy of FISH. The notice states, in part, “…each district shall review the Florida Inventory of School Houses (FISH) and shall certify to the Office of Educational Facilities that the inventory is current and accurate…facilities data…errors can significantly impact funds the district will receive and distort all analyses made from FISH data.” In 2007, the memo to superintendents and facilities planners was first sent on July 25 announcing the October 1 due date for certification (68 days advance notice/reminder of the SREF reporting requirement). A second notice/reminder was sent on September 11 (19 days notice prior to due date). On October 2 all delinquent responders were notified that their certifications were past due. On October 9 all delinquent responders were notified that their certifications were still past due and that a delinquent reminder had been sent. When districts were two weeks past due in certifying the accuracy of FISH, phone calls were made on a daily basis requesting compliance. This same process has been followed in previous years.

Nonetheless, OEF will issue a memo no later than March 31, 2008 to all district superintendents, facilities planners, and FISH managers regarding the IG report. The memo will detail the IG report findings; additionally, the memo will specify the types of spaces typically identified as problem areas according to the IG report.
It should be noted that the IG report dealt solely with maintenance funding, which is, by comparison, a relatively small amount that deals with NSF. Funding sources for public school facilities that provide new construction, remodeling, and renovation, activities that add or upgrade classrooms, are significantly greater and represent the primary use of FISH, e.g. Class Size Reduction and Classrooms For Kids.

Finding 1, Recommendation 2: Consider seeking legislative assistance for improved statutory enforcement capabilities for OEF to ensure FISH accuracy.

OEF is taking this recommendation under advisement and studying ways to secure legislative assistance for compliance with all regulatory issues pertaining to public school facilities matters.

In the IG finding 2 Condition section, the report notes that districts did not follow FISH manual guidelines established by OEF to assure accurate inventory data; the Criteria section states that the FISH manual defines processes for facility inventory maintenance; and the Cause section affirms that the Department does not have enforcement authority to assure accuracy of FISH data.  We concur with the IG assessments on these issues.

Finding 1, Recommendation 3: Amend validation procedures to focus testing more on large spaces and more schools.

OEF does not agree with this recommendation.  OEF procedures treat all spaces equally for validation purposes.  Although stratification and prioritization is useful for audit purposes, ensuring data quality requires emphasis on all data that is collected and maintained.   

See also the response to Finding 1, Recommendation 4 below for more details on the numbers of schools included in validation studies.

Finding 1, Recommendation 4: Develop statistically valid sampling methods to project district-wide variances and potential funding errors based on testing.

OEF does not agree with this recommendation.  OEF validation procedures extend beyond determining the accuracy of the square footage measurements.  The approach relies on selecting a representative of each type of school, i.e. elementary, middle, and high schools; a representative of each school size, i.e., small, medium, and large; and representative schools based on age.  This method is applied so that at least five percent of the space is validated.  The sampling methodology recommended in the IG finding would not be practical to implement as noted in the IG report in Appendix A, “We planned to conduct a statistically valid, random sample of all spaces in a district, but this was logistically implausible as it meant visiting up to 70 percent of a district’s schools and, in some cases, visiting a school to measure only a single room in the sample.” 

OEF currently follows the recommendation to use documented variances noted during the survey as a basis for estimating district-wide variances.    

Finding 1, Recommendation 5: Target areas which are more likely to have significant variances by focusing on the following:

•	Schools with little or no covered walkway and/or inside circulation space recorded in the FISH and schools with a lopsided ratio of covered walkway to inside circulation.
OEF does not agree that there is a correlation of the ratio between inside circulation and covered walkways.  The FISH sample used by the IG during the audit was not large enough to produce a statistically valid basis of correlation between these spaces.  However, OEF will continue to emphasize accuracy in the measurement of the spaces identified above.   
•	Large spaces, open classroom designs, and relocatables (100 percent). 
Large, open and irregularly-shaped spaces are more difficult to measure and variances may occur.  OEF will continue to review its procedures in order to improve validation studies.

Finding 2 – Districts are not complying with the FISH Manual.
Condition:	Six FISH Manual guidelines applicable to accurate inventory practices were not followed by the districts.  Details are provided in Appendix C.	
Criteria:	The FISH Manual defines how facility inventory should be maintained in the areas of building and room definition, relocatable numbering, record updating, floor plans, and primary classroom location.  Details are provided in Appendix D.	
Cause:	DOE policy and procedure was not followed.  District management has not prioritized the need for thorough and complete documentation.  The Department lacks any enforcement mechanisms to ensure that districts assure accuracy.	
Effect:	Spaces were recorded and funds were allocated based on improperly recorded data.  Overstated variances exceeding one thousand square feet (incorrectly or improperly recorded) amounted to 357,446 SF (8.2 acres).  Movable physical asset records were not properly maintained.  Floor plan and FISH information provided inaccurate and untimely information.  Facilities insurance coverage based on inaccurate FISH data could result in claims losses or wasted premiums.	
Recommendation:	The Office of Educational Facilities should: 
•	Emphasize to districts’ boards and superintendents the importance of timely and accurate FISH data collection along with the funding opportunities missed by understated space, 
•	Consider seeking legislative assistance for improved statutory enforcement capabilities for OEF to ensure FISH Manual compliance, and 
•	Ensure Brevard District corrects the Mechanical Room errors for Eau Gallie High School.  	
Management
Response:	Finding 2, Recommendation 1: Emphasize to districts’ boards and superintendents the importance of timely and accurate FISH data collection along with the funding opportunities missed by understated space, 

See the response to Finding 1, Recommendation 1.

Finding 2, Recommendation 2: Consider seeking legislative assistance for improved statutory enforcement capabilities for OEF to ensure FISH Manual compliance.

See the response to Finding 1, Recommendation 2.

Finding 2, Recommendation 3: Ensure Brevard District corrects the Mechanical Room errors for Eau Gallie High School.

Brevard County School District provides an example of the need for legislative action recommended in Findings 1 and 2.  Brevard County School District’s initial certification was 38 days past due.  Although the superintendent and board chair signed the certification at least five days before the due date, district staff did not submit the form until November 7 and OEF did not receive the official copy until November 14, resulting in an official certification that was 44 days overdue.  Brevard County School District staff incorrectly cited a DOE requirement to validate its FISH data as justification for the late submittal.  Corrective action is underway for the errors noted at Eau Gallie High School.  It is anticipated that this will be completed by March 31, 2008.

Finding 3 – OEF validation procedures warrant improvement.

Condition:	OEF validation documentation, for three districts completed during 2006-07, contained mathematical and verification errors.  We noted errors in six of the seven school’s documentation as follows:
•	Transposition errors in calculation for four schools (a room number mistakenly used as square footage and square footage for five spaces left out of the school sums).  Unlike individual classrooms, determining Covered Walkway and Inside Circulation square footage often requires locating and summing numerous measurement amounts from multiple pages of data; this process increases the probability of errors.
•	Arithmetic errors in multiplying a space’s area (length times width) and in summing multiple measurements at five schools.
•	Undeterminable errors in calculating space, summing spaces, or a combination of both.
•	Three of the eleven Inside Circulation spaces were not checked off as having been validated at one school.
Management informed us that use of data export functions available in the new .NET version of the FISH software will reduce data extraction errors.	
Criteria:	Prudent business practices require that financial and operating records and reporting contain accurate, reliable, and complete information to make informed and useful decisions.  Written procedures are an essential component of the Department’s internal control structure that help ensure management directives are carried out.  They should be prepared and regularly maintained to assist management control processes and provide direction to staff.	
Cause:	There may have been inattention to detail and a lack of review and verification of calculations.  Poorly formatted reports made accurate data extraction challenging.  There are no written policies and procedures for the OEF validation procedures.	
Effect:	Arithmetic errors resulted in the OEF validation work producing a Covered Walkway amount which overstated the space by 3,912 SF for one school and understating the Covered Walkway amount at another school by 1,736 SF.  At a third school, OEF arithmetic errors incorrectly yielded a 5.7% (1,481 SF) Covered Walkway understatement which should have been a 1.0% (286 SF) overstatement.  Adding the 1,481 SF to the FISH would result in overstating Covered Walkway by 1,195 SF.  Funding inaccuracies would have occurred as a result of these errors.	
Recommendation:	The Office of Educational Facilities should:
•	Implement written procedures for validations to ensure accurate work and reporting.
•	Utilize the capabilities of the new .NET FISH system to export flat files into spreadsheets for easy formatting and specific data filtering (especially Covered Walkway and Inside Circulation).
•	Create a simple form to record multiple measurements for large space and use spreadsheets for re-computation and review of calculations.	
Management
Response:	Finding 3, Recommendation 1: Implement written procedures for validations to ensure accurate work and reporting.

Written procedures have been in place and used since 2002.  However; the 2007 Legislative requirement that OEF conduct the Educational Plant Survey for 35 consortium districts will require a review and revision of the current validation procedures.  The revised procedures will address the statutory provision, identify processes for the staff performing the validation, and identify unique issues requiring attention during the performance of a validation study.  Revised procedures will be completed by June 30, 2008.

Finding 3, Recommendation 2: Utilize the capabilities of the new .NET FISH system to export flat files into spreadsheets for easy formatting and specific data filtering (especially Covered Walkway and Inside Circulation).

The recommended change is currently in process.  Excel spreadsheets were used for this type of analysis prior to the development of the current system in order to filter FISH data for relevance, accuracy, and type of space. 

See also OEF comments and examples in the Finding 3, Recommendation 3 response.

Finding 3, Recommendation 3: Create a simple form to record multiple measurements for large space and use spreadsheets for re-computation and review of calculations.

The recommended change is currently in process, not only for large spaces, but for all spaces reviewed during a validation study.  Excel spreadsheets were used for this type of analysis prior to the development of the current system in order to filter FISH data for relevance, accuracy, and computation of results and values.  The form for space review is a simple spreadsheet with all relevant facility information and including space for notation regarding necessary changes.  The form used to analyze instructional spaces determines whether districts meet the threshold for 95 percent accuracy in reporting classroom spaces.  A simpler form is used to determine accuracy for reporting net square footage.  The Constitutional Amendment and Florida Statutes have placed primary attention on class size and instruction; therefore, nearly all assessments focus, by design, on the primary goals of the state: classrooms and instructional spaces.  Nonetheless, OEF has always given emphasis to all spaces when validating FISH in order to ensure data quality throughout the inventory.

OEF will continue to review forms and spreadsheets for improvements that will significantly impact the quality and efficiency of the processes.

Closing Comments

The Office of the Inspector General would like to recognize and acknowledge Department staff for their assistance during the course of this audit.  Fieldwork was greatly facilitated by the complete cooperation of all personnel involved. 

Appendix A: Background
Our audit objective was to evaluate the accuracy of the FISH square footage data.  We designed and conducted our validation procedures in order to independently evaluate, and not replicate, OEF’s procedures.
We purposely used different methods from those used by OEF to select schools to validate the FISH inventory and used statistically-valid, random sampling of spaces rather than testing all school spaces.  We selected three districts’ data and facilities to review; Brevard, Seminole, and Leon, the 10th, 11th, and 23rd largest districts, respectively, ranked by full-time equivalents.  All three districts were validated by OEF during 2006-07.  Leon was in compliance, but Brevard and Seminole failed the OEF validations.  The schools in each district previously validated by OEF were excluded as candidates for our testing.  We planned to conduct a statistically valid, random sample of all spaces in a district, but this was logistically implausible as it meant visiting up to 70% of a district’s schools and, in some cases, visiting a school to measure only a single room in the sample.  After discussions with the Director of OEF, we decided the population to be sampled would be limited to spaces of at least 600 square feet (SF).  There are no classrooms smaller than 600 SF, and almost any measurement variances for spaces less than 600 SF would be immaterial compared to a school’s NSF.
We decided to test ten schools from each district.  The number of each type school (elementary, middle, or high) was based on a weighted average of the number of rooms of each type.  Five elementary and two middle schools were selected from all three districts.  Three high schools were selected from Brevard and Seminole; and two high schools and one technical center were selected from Leon.  Within each type, schools were selected based on such judgmental factors as: larger enrollments, school age (preferably a new, a middle-aged, and an old), frequency of facility changes (i.e., remodeling and/or new construction), Inside Circulation (IC - inside hallways) and Covered Walkway (CW - exterior covered sidewalks) NSF totals as well as the IC/CW ratio, and proximity to other school types.  OEF’s documentation demonstrated validation failures (net square footage variance from FISH exceeds five percent) usually resulted from large variances in Covered Walkway and Inside Circulation spaces.  We noted in our research five schools had no Covered Walkway space recorded in FISH; yet, the schools’ photographs on their respective websites showed Covered Walkway areas.
After selecting validation candidates, we generated a statistically valid, random sample of spaces for each school.  We sampled a total of 1,186 spaces (2.7 million NSF per FISH) from the thirty schools.  Spaces are classified per the FISH by Design Description (e.g., Primary Classroom, Dining Area, Gymnasium).  During our validation fieldwork, we amended the sample to include additional large spaces and relocatable buildings as we repeatedly noted reportable variances in these spaces.  Large spaces, those exceeding 2,100 SF, include Covered Walkways, Inside Circulation, gyms, auditoriums, food service (kitchen and dining) areas, libraries, and elementary covered play areas.  In testing relocatable buildings, we often could not locate FISH-listed buildings; and conversely, we located buildings not listed in FISH.

Appendix B: Finding 1
The summed errors (positive and negative netted) alone do not illustrate the size of the errors noted.  The table below documents the summed district variances.  Note the two percentage outliers: Brevard’s overstated (negative) variance easily exceeded one-quarter of the FISH at 27.9 percent and Seminole’s understated (positive) variance was almost one-third of the FISH at 32.9 percent.
Dist	Summed Variance	Summed %	Negative Variance	Negative %	Positive Variance	Positive %	
Brevard	(187,910)	(16.1)	(324,784)	(27.9)	136,874	11.7	
Leon	18,967	2.8	(42,684)	(6.2)	61,651	8.9	
Seminole	231,630	27.5	(46,135)	(5.5)	277,765	32.9	
The overall understatement is all from high schools.  The high (HS) schools’ SF variance was 5.6 times the combined elementary (ES) and middle (MS) schools’ total.  The total variance for both ES and MS was an overstatement of 2.7 percent; the HS total variance was an understatement of 23.4 percent.  This statistic is even more remarkable considering we tested fifty-four percent more space in the combined elementary and middle schools than was tested in HS.  Furthermore, we tested eight high schools, and only one had an immaterial variance of 1.1 percent; the variances for the other seven ranged from 9 to 77 percent.  To put this in perspective, a small high school-sized space (226,731 SF) was missing from the FISH records for the remaining seven high schools.
In the FISH, rooms are classified by Design Description.  The table below details the first and third largest variances in total square feet by Design Description.  Although we tested over seven times more Intermediate/Middle Classrooms than Covered Walkway spaces, the total variance for Covered Walkway was thirty-seven times greater than that for Intermediate/Middle Classrooms and for the average variance per space, it was two hundred sixty-eight times greater.
Design Description	SF Variance (over)/understated	NSF Tested	Spaces Measured	Average SF Variance	
Covered Walkway	297, 378
or 6.8 acres	678,955	30	9,913	
Intermediate/Middle Classroom	(8,002)	182,257	215	37	

The table below further illustrates the significant difference in the spaces noted above.  The Covered Walkway SF space tested was ten times the number of spaces tested on a percentage basis.  Conversely, Intermediate/Middle Classroom space tested was one-third the number of spaces tested on a percentage basis.
Design Description	Percentage of NSF Tested	Percentage of Spaces Tested	
Covered Walkway	25.2	2.5	
Intermediate/Middle Classroom	6.8	18.1	

The average variance for an Intermediate/Middle Classroom was 6 x 6 feet square; while, the average variance for a Covered Walkway space was 100 x 100 feet square (a high school gym).  Nearly fifty-seven percent of the Covered Walkway variance is attributable to five schools which had Covered Walkway space (168,473 SF), but none was recorded in FISH.  Additionally, other significant over- and under-statements were noted.  Four schools’ Covered Walkway variances were overstated by twenty-two to fifty-nine percent totaling 80,643 SF.  Conversely, eight schools’ Covered Walkway variances were understated by thirty-four to ninety-five percent totaling 181,830 SF.  Seventeen Inside Circulation spaces were overstated by thirty-five to one hundred percent totaling 125,014 SF, and seven spaces were understated by twenty-eight to seventy-nine percent totaling 20,076 SF.
The only classroom areas where we noted reportable variances were in open classroom facilities.  We tested two schools which had open classrooms per the Design Description.  One had immaterial variances in all six spaces tested.  In the second school, the variances for the five spaces tested ranged between sixty and sixty-three percent.  Additionally, we tested two other schools whose classrooms’ Design Description were not open, but the buildings were of an open design.  Twenty-one spaces tested had reportable variances.  The three schools with reportable variances had the highest percentages of variances (65.6, 73.3, and 75.0) exceeding five percent for all thirty schools tested.

Appendix C: Finding 2 Condition
We noted the following:
Space specifically excluded by the FISH Manual was improperly recorded in the inventory.  Nine mechanical spaces in Brevard’s Eau Gallie High School totaling 127,367 SF were recorded in FISH.  Air conditioning compressor units were located on the school’s original flat roof.  In 1999, a new pitched, metal roof was constructed to cover the almost three acre area of the roof, and this space was subsequently recorded in FISH.  This space should not be recorded because: 1) the new space was incidental to the new roof’s purpose (dry educational spaces), and 2) the FISH Manual specifically excludes this type of space.
Relocatable building number assignment rules were not followed consistently.  Seventeen of the FISH-recorded buildings could not be located; while, twenty buildings were located which were not recorded in FISH.  Another building had two unique FISH numbers posted and both numbers were recorded in FISH.  Although all spaces are required to be numbered, relocatable rooms were un-numbered or contained multiple numbers.  Seventeen relocatable restrooms located were not recorded in FISH.
Building changes (remodeling or demolition) were not recorded in FISH.  Twenty spaces had either been enlarged by removing existing walls and combining multiple spaces, or shrunk by adding new walls and dividing one space into multiple spaces .  One permanent, concrete building (4,766 SF) at a high school could not be located.
Floor plan information was inaccurate in two areas.
o	Sidewalks were identified on floor plans but the Covered Walkways were not.  Floor plans often did not differentiate between Covered and un-Covered Walkways.  Floor plans could not be relied upon to locate Covered Walkway space.
The plans as drawn for three high schools matched the physical structures, but the FISH room numbering did not.  The floor plans for two of the three were so inaccurate they could not be used to locate spaces in some buildings.  Room information on the floor plans did not match either the physical structure as built or the FISH.  If present, relocatables were often not found on floor plans.  Also, many floor plans were not current.  Eleven of the twenty floor plans from two districts were dated between 1988 and 1994.  The third district’s floor plans were recent.
Two recorded spaces did not meet the building definition requiring walls, floor, and roof.  We noted these exterior electrical/mechanical spaces were areas surrounded by block walls with neither floor nor roof.
We noted fifteen Primary Classrooms on the second floor of buildings in three elementary schools although Primary Classrooms are not supposed to be located above the first floor.

Appendix D: Finding 2 Criteria
The FISH Manual states in part:
in §8 – Room Functionality (page 46), under 8a - Room Number, “NOTE: Mechanical and electrical spaces that are in attics, on roofs, or beneath floors in crawl spaces, enclosures constructed above stages, storage areas in warehouses or other areas that are above ground level but not a structural story of the building should not be reported as rooms in FISH.”
in §8 – Room Functionality (page 46), under 8a - Room Number, “All relocatable units should be assigned a building and room number in which the building number identifies the ownership of the unit.  The unique building and room numbers should remain with the relocatable unit regardless of the facility site.”
in §1 – Introduction (page 5), “A district’s facilities inventory may be corrected at any time when new additions or remodeling occurs, during a validation study conducted by the district or the Office of Educational Facilities (OEF), or as the result of an educational plant survey.”
in §13 – Appendixes (page 72), under Floor Plans, “All Covered Walkways attached to a building should be identified on the floor plan (see examples in Appendix A). . . .  NOTE: All spaces should be numbered using FISH numbers as recorded in the inventory including store rooms, restrooms, corridors, etc.”
in §12.5 – Definitions (page 66), “BUILDING: A structure, either permanent or relocatable, consisting of constructed walls, roof, and floor.”
in §12.5 – Definitions (page 69), under PRIMARY CLASSROOM:, “NOTE: A primary classroom should not be located above the first floor.”

MANAGEMENT RESPONSE – ATTACHMENT
PROCEDURES FOR ONSITE REVIEW OF 5 PERCENT; 1013.31(1)(b)1

Salient Points:
•	A school district’s educational plant survey must be updated at least once every five years.
•	To ensure that the data reported to the Department of Education is correct:
•	The Department shall annually conduct an onsite review of 5 percent of the facilities reported for each school district completing a new survey that year.
•	If the Department’s review finds the data reported by a district is less than 95 percent accurate, within 1 year from the time of notification by the Department the district must submit revised reports correcting its data.
•	If a district fails to correct its reports, the Commissioner may direct that future fixed capital outlay funds be withheld until such time as the district has corrected its reports so that they are not less than 95 percent accurate.

Issues To Address:
•	Select all districts completing a new survey within the year.
•	Review FISH data and select at least a 5 percent sampling to include appropriate representation of each grade grouping.
•	Select some facilities that are old, some that are new.
•	Select schools where there is a large concentration of relocatables and schools where none or very few relocatables are reported.
•	Consider schools with high concentrations of ESE spaces and schools reported to serve as attendance zones for ESE.
•	From the survey, look at remodeling recommendations for +/- student stations.
•	Look at new construction recommendations for student stations to see if what is recommended reflects what is needed, e.g., ESE suite containing several classrooms but few student stations.
•	Look at new construction recommendations for non-student station carrying spaces to see if what is recommended reflects what is needed, e.g., new administrative suite, auditorium, multipurpose PE room, etc.
•	Look at renovation recommendations of all space to see if what is recommended reflects what is needed.

•	Review for minus student stations in remodeling that have the same space recommended for new construction to see if what is recommended reflects what is needed.
•	Review recommendations for remodeling a space to a different use and then recommending building the same type space as new construction to see if what is recommended reflects what is needed, e.g., recommend converting a media center to administration and then recommend building a new media center.
•	Look for recommending transferring relocatables to district or other use and then recommending building new classrooms to replace relocatables. (When relocatables will not be moved and new permanent construction will not occur because the recommendation is not a feasible work plan or option within the financial capabilities of the district)
•	Look at the age of buildings when considering remodeling, renovation, and new additions.
•	Compare projected COFTE to existing student stations on a school-by-school basis.
•	Compare projected COFTE to existing student stations at the district level. (COFTE projections and student stations should be comparable)
•	Check all instructional spaces to see if student stations should/should not be assigned.
•	Check all non-instructional spaces that are classroom-size (460 NSF or larger) to see if student stations should be assigned.
•	Review all design codes for accuracy.
•	Review all spaces and compare to FISH for NSF reporting accuracy.
•	Compare data reported in FISH to all actual existing space for accuracy.
•	Check Table II for transfer/receipt of COFTE and +/- student stations.
•	Check age of buildings for any space listed as unsatisfactory and make sure the coding is correct. (Castaldi formula approval to replace a building does not make a space unsatisfactory; only space that meets the definition of “unsatisfactory” in the FISH users manual should be reported as such)
•	Calculate the percentage of NSF changed and the percentage of student stations changed as a result of the onsite review; if either NSF or student stations are less than 95 percent accurate, the district will be required to correct all data in all facilities. (When calculating percent of change, reductions in NSF or student stations will be calculated as positive numbers, e.g., if a room of 900 NSF is deleted and another room of 900 NSF is added, the calculation to determine accuracy will be 1800 NSF changed)