Performance Audit, Safford Unified School District

              Performance Audit
Division of School Audits
A REPORT
TO THE
ARIZONA LEGISLATURE
September • 2015
Report No. 15-211
Debra K. Davenport
Auditor General
Safford Unified
School District
The Auditor General is appointed by the Joint Legislative Audit Committee, a bipartisan committee composed of five senators and five
representatives. Her mission is to provide independent and impartial information and specific recommendations to improve the opera-tions
of state and local government entities. To this end, she provides financial audits and accounting services to the State and political
subdivisions, investigates possible misuse of public monies, and conducts performance audits of school districts, state agencies, and
the programs they administer.
The Joint Legislative Audit Committee
Audit Staff
Ross Ehrick, Director
Ann Orrico, Manager and Contact Person
Jennie Snedecor, Team Leader
Jessica Cupero
Nate Robb
Joshua Roloson
Alexa Tavasci
The Auditor General’s reports are available at:
www.azauditor.gov
Printed copies of our reports may be requested by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410 • Phoenix, AZ 85018 • (602) 553-0333
Representative John Allen, Vice Chair
Representative Regina Cobb
Representative Debbie McCune Davis
Representative Rebecca Rios
Representative Kelly Townsend
Representative David Gowan (ex officio)
Senator Judy Burges, Chair
Senator Nancy Barto
Senator Lupe Contreras
Senator David Farnsworth
Senator Lynne Pancrazi
Senator Andy Biggs (ex officio)
2910 NORTH 44th STREET • SUITE 410 • PHOENIX, ARIZONA 85018 • (602) 553-0333 • FAX (602) 553-0051
September 16, 2015
Members of the Arizona Legislature
The Honorable Doug Ducey, Governor
Governing Board
Safford Unified School District
Mr. Ken VanWinkle, Superintendent
Safford Unified School District
Transmitted herewith is a report of the Auditor General, A Performance Audit of the Safford Unified
School District, conducted pursuant to A.R.S. §41-1279.03. I am also transmitting within this report
a copy of the Report Highlights for this audit to provide a quick summary for your convenience.
As outlined in its response, the District agrees with all of the findings and recommendations.
My staff and I will be pleased to discuss or clarify items in the report.
Sincerely,
Debbie Davenport
Auditor General
Similar student achievement and efficient operations
overall
September • Report No. 15-211
2015
In fiscal year 2013, Safford
USD’s student achievement
was similar to peer districts’,
and the District operated
efficiently overall with costs
that were lower than or similar
to peer district averages.
Safford USD’s administrative
cost per pupil was similar to
the peer districts’ average,
but the District needs to
strengthen controls over
its computer systems and
network. The District’s
plant operations costs
were much lower than peer
districts’, primarily because
the District employed fewer
plant staff, used energy-and
water-saving practices,
and made efficient use of
building space. In addition,
the District’s food service
program was self-sufficient,
operating with a cost per
meal that was similar to the
peer district average, and
its transportation program
was reasonably efficient,
with routes filling buses to
76 percent of capacity and
drivers performing other
duties, such as maintenance,
when not driving.
REPORT HIGHLIGHTS
PERFORMANCE AUDIT
Our Conclusion
Safford Unified
School District
Student achievement similar to peer
districts’—In fiscal year 2013, Safford
USD’s student AIMS scores in math,
reading, and writing were slightly higher
than the peer districts’ averages, and its
science scores were similar. Under the
Arizona Department of Education’s A-F
Letter Grade Accountability System, the
District received an overall letter grade
of B. Twelve of the 22 peer districts also
received Bs, 2 peer districts received
As, 5 peer districts received Cs, and 3
peer districts received Ds. Additionally,
the District’s 67 percent graduation
rate was lower than the peer districts’ 81 percent average and the State’s 75 percent
average.
Efficient operations overall—In fiscal year
2013, Safford USD operated efficiently
overall, with costs that were lower than, or
similar to, peer district averages. Operating
efficiently allowed the District to spend 11
percent, or $398, more per pupil in the
classroom than peer districts, on average,
despite spending less per pupil overall. The
District’s administrative cost per pupil was
similar to the peer districts’ average, and its
plant operations costs were much lower primarily because the District employed fewer
plant operations staff, used energy- and water-saving practices, and made efficient use
of building space. In addition, the District’s food service program was self-sufficient,
operating with a cost per meal that was similar to the peer district average, and its
transportation program was reasonably efficient, with routes filling buses to 76 percent
of capacity and drivers performing other duties, such as maintenance, when not driving.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Math Reading Writing Science
Safford USD Peer group State-wide
Percentage of students who met or
exceeded state standards (AIMS)
Fiscal year 2013
Safford USD
Table 1:
􀀃􀀃􀀃􀀃􀀃􀀃􀀃
Safford
USD
Peer
group
average
Administration $779 $764
Plant operations 589 921
Food service 328 364
Transportation 226 394
Comparison of per pupil expenditures
by operational area
Fiscal year 2013
In fiscal year 2013, Safford USD lacked adequate controls over its computer systems
and network. Although no improper transactions were detected in the items auditors
reviewed, these poor controls exposed the District to an increased risk of errors, fraud,
unauthorized access to sensitive information, and loss of data. More specifically:
• Broad access to accounting system—Twenty-five of the District’s 36 accounting
system users had more access to the system than they needed to perform their job
duties, including 24 employees who had the ability to perform all accounting system
District needs to strengthen its computer controls
REPORT HIGHLIGHTS
PERFORMANCE AUDIT
September 2015 • Report No. 15-211
A copy of the full report is available at:
www.azauditor.gov
Contact person:
Ann Orrico (602) 553-0333
Safford Unified
School District
functions. Granting employees system access beyond what is required for their job duties, especially full
system access, exposes the District to a greater risk of errors, misuse of sensitive information, and fraud,
such as processing false invoices or adding and paying nonexistent vendors or employees.
• Generic accounts—We found that 18 network accounts, 4 accounting system accounts, and 1 student
information system account were unnecessary, active generic accounts not assigned to specific users,
making it difficult or impossible to hold anyone accountable if inappropriate activity occurred while using
these accounts.
• Inappropriate server room access—The District’s servers were stored in a room next to its IT department
offices, which was secured by lock and key. However, the server room was accessible to custodial and other
non-IT staff who were assigned master keys to the District’s facilities, which increased the risk of network
interruption due to intentional or accidental equipment damage.
• Lack of a disaster recovery plan—The District lacked a written, up-to-date, and tested disaster recovery
plan for its network and critical financial and student information systems. Having a written and properly
designed disaster recovery plan would help ensure continuous accessibility to sensitive and critical data in
the event of a system or equipment failure or interruption.
The District should:
• Modify employee access to its accounting system to ensure that an employee cannot initiate and complete
a transaction without independent review and approval.
• Eliminate unnecessary generic user accounts in its network and systems and properly control any remaining
generic accounts.
• Limit physical access to its computer server room.
• Create and test a formal disaster recovery plan.
Recommendations
Arizona Office of the Auditor General
Page i
TABLE OF CONTENTS
District Overview 1
Student achievement similar to peer districts’ and state averages 1
District operated efficiently overall 1
Finding 1: District needs to strengthen controls over computer
systems and network 3
Increased risk of unauthorized access to critical computer systems and network 3
Lack of disaster recovery plan could result in interrupted operations or data loss 4
Recommendations 4
Appendix
Objectives, Scope, and Methodology a-1
District Response
Table
1 Comparison of per pupil expenditures by operational area
Fiscal year 2013
(Unaudited) 2
Figure
1 Percentage of students who met or exceeded state standards (AIMS)
Fiscal year 2013
(Unaudited) 1
Safford Unified School District • Report No. 15-211
Safford Unified School District • Report No. 15-211 Arizona Office of the Auditor General
Safford Unified School District is a medium-large sized, rural district located in eastern Arizona in
Graham County. In fiscal year 2013, the District served 3,057 students in kindergarten through 12th
grade at its six schools, including 3 elementary schools, 1 middle school, 1 high school, and 1
alternative high school.
In fiscal year 2013, Safford USD’s student achievement was similar to peer districts’, and the District
operated efficiently overall with most costs lower than, or similar to, the peer districts’ averages.1
The District’s administrative cost per pupil was similar to the peer districts’ average, and its plant
operations and food service program operated efficiently. Further, despite a higher cost per rider, the
District’s transportation program was reasonably efficient. However, the District should strengthen
controls over its computer network and systems.
Student achievement similar to peer districts’ and state averages
In fiscal year 2013, 66 percent of the District’s
students met or exceeded state standards
in math, 83 percent in reading, 57 percent in
writing, and 60 percent in science. As shown
in Figure 1, Safford USD’s math, reading,
and writing scores were slightly higher than
peer district averages, and its science scores
were similar. Under the Arizona Department of
Education’s A-F Letter Grade Accountability
System, Safford USD received an overall letter
grade of B for fiscal year 2013. Twelve of the 22
peer districts also received Bs, 2 peer districts
received As, 5 peer districts received Cs, and
3 peer districts received Ds. The District’s 67
percent graduation rate in fiscal year 2013
was lower than the peer districts’ 81 percent
average and the State’s 75 percent average.
District operated efficiently overall
As shown in Table 1 and based on auditors’ review of various performance measures, Safford USD
operated efficiently overall in fiscal year 2013 with costs that were similar to, or lower than, peer
district’s average costs in all operational areas. Operating efficiently allowed the District to spend 11
1 Auditors developed three peer groups for comparative purposes. See page a-1 of this report’s Appendix for further explanation of the peer groups.
DISTRICT OVERVIEW
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Math Reading Writing Science
Safford USD
Peer group
State-wide
Figure 1: Percentage of students who met or
exceeded state standards (AIMS)
Fiscal year 2013
(Unaudited)
Source: Auditor General staff analysis of fiscal year 2013 test results on
Arizona’s Instrument to Measure Standards (AIMS).
Page 1
Arizona Office of the Auditor General
Page 2
Safford Unified School District • Report No. 15-211
percent, or $398, more per pupil in the classroom
than peer districts, on average, despite spending
less per pupil overall. Safford USD spent less, in
part, because it received less federal grant monies,
such as Title I, than the peer districts averaged
because its poverty level was 6 percent lower than
the peer districts’ average.
Similar administrative costs but some
improvements needed—Safford USD’s
$779 administrative cost per pupil was similar
to the peer districts’ $764 per pupil average.
However, auditors identified some computer
systems and network controls that need
strengthening (see Finding 1, page 3).
Much lower plant operations costs—
Compared to peer districts’ averages, Safford
USD’s fiscal year 2013 plant operations costs
were 30 percent lower per square foot and 36
percent lower per student. The District spent less on plant operations primarily because some
plant employees spent part of their time on student transportation, driving daily bus routes.
As a result, the District employed fewer plant operations staff per square foot than the peer
districts’ average. The District also used low-cost irrigation and desert landscaping to keep
its water costs much lower than the peer districts’ average. In addition, the District kept its
energy costs low partly because in fiscal year 2013, the District began controlling energy
usage through a central energy management system that monitored and adjusted building
temperatures to keep them within district-approved ranges. The District also upgraded its
lighting to energy-efficient lighting fixtures. Finally, the District made efficient use of its building
space by using an average of 80 percent of its building capacity.
Efficient food service program—Safford USD’s $2.58 cost per meal was similar to the
peer districts’ average of $2.67, and its cost per pupil was 10 percent lower. The District kept
its costs down and maintained a self-sufficient program partly by negotiating favorable terms
with its food service vendor, including paying substantially less for salaries and benefits than
the average for the peer districts that also outsourced their food service operations.
Transportation program reasonably efficient—Safford USD’s $3.43 cost per mile was
4 percent lower than the peer districts’ $3.58 average, and its $634 cost per rider was 37
percent higher than the peer districts’ $462 average. The District’s cost per rider was higher
partly because it transported 27 percent fewer riders than the peer districts, on average,
and therefore, certain costs, such as the transportation director’s salary, were spread over
fewer riders when calculating the cost per rider. Despite the higher cost per rider, the District
operated reasonably efficient bus routes, filling buses to 76 percent of seat capacity, on
average. In addition, the District employed other cost-saving measures, including having its
drivers perform other duties, such as maintenance, at the District when not driving.
Safford USD
Table 1:
Spending
Safford
USD
Peer
group
average
State
average
Total per pupil $6,770 $7,187 $7,496
Classroom dollars 4,177 3,779 4,031
Nonclassroom
dollars
Administration 779 764 746
Plant operations 589 921 924
Food service 328 364 396
Transportation 226 394 369
Student support 366 561 582
Instruction
support 305 404 448
Table 1: Comparison of per pupil
expenditures by operational area
Fiscal year 2013
(Unaudited)
Source: Auditor General staff analysis of fiscal year 2013 Arizona
Department of Education student membership data and
district-reported accounting data.
Arizona Office of the Auditor General
Page 3
Safford Unified School District • Report No. 15-211
District needs to strengthen controls over computer
systems and network
In fiscal year 2013, Safford USD lacked adequate controls over its computer systems and network.
Although no improper transactions were detected in the items auditors reviewed, these poor
controls exposed the District to an increased risk of errors, fraud, unauthorized access to sensitive
information, and loss of data.
Increased risk of unauthorized access to critical computer systems
and network
Weak controls over user access to the District’s accounting and student information systems and
computer network increased the risk of unauthorized access to these critical systems. Specifically:
• Broad access to accounting system—Auditors reviewed the District’s accounting system user
access report for all 36 users and identified 25 district employees who had more access to the
accounting system than they needed to perform their job duties, including 24 employees who
had the ability to perform all accounting system functions. Although no improper transactions
were detected in the 30 payroll and 30 accounts payable transactions auditors reviewed,
granting employees system access beyond what is required for their job duties, especially full
system access, exposes the District to a greater risk of errors, misuse of sensitive information,
and fraud, such as processing false invoices or adding and paying nonexistent vendors or
employees.
• Generic accounts—Auditors also reviewed the District’s user access reports for its network
and systems and found that 18 network accounts, 4 accounting system accounts, and 1
student information system account were unnecessary, active generic accounts. Having
generic accounts creates additional risk because they are not assigned to specific individuals
and therefore make it difficult or impossible for the District to hold anyone accountable if
inappropriate activity were conducted using these accounts. The District should eliminate all
unnecessary generic accounts and minimize the number of generic accounts it maintains and
establish proper controls over them, such as disabling them when not being used.
• Inappropriate server room access—The District did not sufficiently protect its server room.
The District’s servers were stored in a room next to its IT department offices, which was secured
by lock and key. However, the server room was accessible to custodial and other non-IT staff
who were assigned master keys to the District’s facilities, which increased the risk of network
interruption due to intentional or accidental equipment damage.
FINDING 1
Arizona Office of the Auditor General
Page 4
Safford Unified School District • Report No. 15-211
Lack of disaster recovery plan could result in interrupted
operations or data loss
The District did not have a written, up-to-date, and tested disaster recovery plan for its network
and critical financial and student information systems. A written and properly designed disaster
recovery plan would help ensure continued operation in the case of a system or equipment
failure or interruption. The plan should include detailed information on how to restore systems in
such an event. As part of a disaster recovery plan, the District should also perform documented
tests of its ability to restore electronic data files from data backups, which are important to
ensure continuous accessibility to sensitive and critical data.
Recommendations
1. The District should limit employees’ access to the accounting system to only the access
necessary to meet their job responsibilities to help ensure that no single employee can
complete transactions without an independent review.
2. The District should eliminate unnecessary generic user accounts in its network and
systems and properly control any remaining generic accounts.
3. The District should limit physical access to its IT server room so that only appropriate
personnel have access.
4. The District should create a formal disaster recovery plan and test it periodically to identify
and remedy deficiencies.
Arizona Office of the Auditor General
Page a-1
APPENDIX
Safford Unified School District • Report No. 15-211
Objectives, Scope, and Methodology
The Office of the Auditor General has conducted a performance audit of the Safford Unified School
District pursuant to Arizona Revised Statutes §41-1279.03(A)(9). Based in part on their effect on
classroom dollars, as previously reported in the Office of the Auditor General’s annual report, Arizona
School District Spending (Classroom Dollars report), this audit focused on the District’s efficiency
and effectiveness in four operational areas: administration, plant operations and maintenance,
food service, and student transportation. To evaluate costs in each of these areas, only operational
spending, primarily for fiscal year 2013, was considered.1 Further, because of the underlying law
initiating these performance audits, auditors also reviewed the District’s use of Proposition 301 sales
tax monies and how it accounted for dollars spent in the classroom.
In conducting this audit, auditors used a variety of methods, including examining various records,
such as available fiscal year 2013 summary accounting data for all districts and Safford USD’s
fiscal year 2013 detailed accounting data, contracts, and other district documents; reviewing district
policies, procedures, and related internal controls; reviewing applicable statutes; and interviewing
district administrators and staff.
To compare districts’ academic indicators, auditors developed a student achievement peer group
using poverty as the primary factor because poverty has been shown to be associated with student
achievement. Auditors also used secondary factors such as district type and location to further
refine these groups. Safford USD’s student achievement peer group includes Safford USD and the
22 other unified school districts that also served student populations with poverty rates between 20
and 27 percent in towns and rural areas. Auditors compared Safford USD’s graduation rate and its
student AIMS scores to those of its peer group averages. The same grade levels were included to
make the AIMS score comparisons between Safford USD and its peer group. AIMS scores were
calculated using test results of the grade levels primarily tested, including grade levels 3 through 8
and 10 for math, reading, and writing, and grade levels 3 through 12 for science. Generally, auditors
considered Safford USD’s student AIMS scores and graduation rate to be similar if they were within 5
percentage points of peer averages, slightly higher/lower if they were within 6 to 10 percentage points
of peer averages, higher/lower if they were within 11 to 15 percentage points of peer averages, and
much higher/lower if they were more than 15 percentage points higher/lower than peer averages. In
determining the District’s overall student achievement level, auditors considered the differences in
AIMS scores between Safford USD and its peers, as well as the District’s graduation rate and Arizona
Department of Education-assigned letter grade.2
To analyze Safford USD’s operational efficiency in administration, plant operations, and food
service, auditors selected a group of peer districts based on their similarities in district size, type,
1 Operational spending includes costs incurred for the District’s day-to-day operations. It excludes costs associated with repaying debt,
capital outlay (such as purchasing land, buildings, and equipment), and programs such as adult education and community service that are
outside the scope of preschool through grade 12 education.
2 The Arizona Department of Education’s A-F Letter Grade Accountability System assigns letter grades based primarily on academic growth
and the number of students passing AIMS.
Arizona Office of the Auditor General
Page a-2
Safford Unified School District • Report No. 15-211
and location. This operational peer group includes Safford USD and 20 other unified or union
high school districts that also served between 2,000 and 7,999 students and were located in
towns and rural areas. To analyze Safford USD’s operational efficiency in transportation, auditors
selected a group of peer districts based on their similarities in miles per rider and location. This
transportation peer group includes Safford USD and 12 other school districts that also traveled
less than 200 miles per rider and were located in towns and rural areas. Auditors compared
Safford USD’s costs to its peer group averages. Generally, auditors considered Safford USD’s
costs to be similar if they were within 5 percent of peer averages, slightly higher/lower if they
were within 6 to 10 percent of peer averages, higher/lower if they were within 11 to 15 percent
of peer averages, and much higher/lower if they were more than 15 percent higher/lower than
peer averages. However, in determining the overall efficiency of Safford USD’s nonclassroom
operational areas, auditors also considered other factors that affect costs and operational
efficiency such as square footage per student, meal participation rates, and bus capacity
utilization, as well as auditor observations and any unique or unusual challenges the District
had. Additionally:
• To assess the District’s computer information systems and network, auditors evaluated
certain controls over its logical and physical security, including user access to sensitive data
and critical systems, and the security of servers that house the data and systems. Auditors
also evaluated certain district policies over the system such as data sensitivity, backup, and
recovery.
• To assess whether the District’s administration effectively and efficiently managed district
operations, auditors evaluated administrative procedures and controls at the district
and school level, including reviewing personnel files and other pertinent documents and
interviewing district and school administrators about their duties. Auditors also reviewed
and evaluated fiscal year 2013 administration costs and compared these to peer districts’.
• To assess whether the District managed its plant operations and maintenance function
appropriately and whether it functioned efficiently, auditors reviewed and evaluated fiscal
year 2013 plant operations and maintenance costs and district building space, and
compared these costs and capacities to peer districts’.
• To assess whether the District managed its food service program appropriately and whether
it functioned efficiently, auditors reviewed fiscal year 2013 food service revenues and
expenditures, including labor and food costs; compared costs to peer districts’; reviewed
the Arizona Department of Education’s food service-monitoring reports; reviewed point-of-
sale system reports; and observed food service operations. Auditors also reviewed all
documents related to the District’s contract with a food service management company to
operate its food service program, including the fiscal year 2013 contract and all documents
related to the procurement of the contract.
• To assess whether the District managed its transportation program appropriately and
whether it functioned efficiently, auditors reviewed and evaluated required transportation
reports, driver files, bus maintenance and safety records, bus routing, and bus capacity
usage, and reviewed the District’s procedures for purchasing and securing fuel. Auditors
also reviewed fiscal year 2013 transportation costs and compared them to peer districts’
average costs.
Arizona Office of the Auditor General
Page a-3
Safford Unified School District • Report No. 15-211
• To assess whether the District was in compliance with Proposition 301’s Classroom Site Fund
requirements, auditors reviewed fiscal year 2013 expenditures to determine whether they were
appropriate and if the District properly accounted for them. No issues of noncompliance were
identified.
• To assess the District’s financial accounting data, auditors evaluated the District’s internal
controls related to expenditure processing and scanned all fiscal year 2013 payroll and accounts
payable transactions for proper account classification and reasonableness. Additionally,
auditors reviewed detailed payroll and personnel records for 30 of the 477 individuals who
received payments in fiscal year 2013 through the District’s payroll system and reviewed
supporting documentation for 30 of the 8,100 fiscal year 2013 accounts payable transactions.
No improper transactions were identified. Auditors also evaluated other internal controls that
were considered significant to the audit objectives and reviewed fiscal year 2013 spending and
prior years’ spending trends across operational areas.
We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
The Auditor General and her staff express their appreciation to the Safford Unified School District’s
board members, superintendent, and staff for their cooperation and assistance throughout the audit.
DISTRICT RESPONSE
DISTRICT RESPONSE
FINDING 1: District needs to strengthen controls over computer systems and network.
Recommendation 1: The District should limit employees’ access to the accounting system to only the
access necessary to meet their job responsibilities to help ensure that no single employee can complete
transactions without an independent review.
District Response: The District concurs with this finding. Access levels will be defined as needed
based on job positions and appropriate security access will be implemented. The IT Systems
Administrator will be trained on managing access controls for the accounting system by the software
vendor.
Recommendation 2: The District should eliminate unnecessary generic user accounts in its network
and systems and properly control any remaining generic accounts.
District Response: The District concurs with this finding. Generic accounts were reviewed and
unnecessary accounts were eliminated when the audit was still on site. A procedure to review the need
of all accounts each quarter was also put in place. Generic accounts are now limited to:
 Technology testing accounts - necessary to test functionality of different user groups.
 Auto-login student accounts - necessary at the elementary schools so labs can function easily
with young students and in the adult education programs due to sporadic and unpredictable
enrollment. IT controls have been implemented to limit the resources available to these
accounts. These accounts may only log into environments specifically designated for its
intended purpose.
 Auto-login other account - necessary for Time Clock computers since those users do not have
accounts, OPAC library catalogue, District office reception computer for job applications and
lunch applications. Foods accounts because different users run the meal program. IT controls
have been implemented to limit the resources available to these accounts. These accounts may
only log into environments specifically designated for its intended purpose.
 Service accounts - unnecessary accounts were eliminated.
Recommendation 3: The District should limit physical access to its IT server room so that only
appropriate personnel have access.
District Response: The District concurs with this finding. The replacement cores for the locks were
ordered as part of the full District rekeying project. This will limit access to the server room, as well as
campus site MDF’s and IDF’s to appropriate technology personnel only.
Recommendation 4: The District should create a formal disaster recovery plan and test it periodically
to identify and remedy deficiencies.
District Response: The District concurs with this finding. Although the District had a Data Backup and
Recovery plan in place, it was determined during audit this plan was not sufficient as a full disaster
recovery plan with more detail and instruction necessary. The District has obtained copies of full
disaster recovery plans from other school districts that meet the Auditor General's guidelines which is
assisting the District as it amends its plan. Additionally, it is implementing a process for periodic review
and testing of the disaster recovery plan.