Progress Report – MSCS Committed To Greatness

Fiscal & Operational Management Progress

Together with our leadership team and Board, we’ve prioritized assessing the district holistically and aggressively working to address issues and challenges, creating a pathway for greatness.

We learned early on that key shifts needed to be made to ensure that, ultimately, our students receive high-quality education efficiently and innovatively. That includes assessing our operations practices, curriculum, and leadership models that impact them daily, both directly and indirectly.

Under Superintendent Roderick Richmond’s leadership, we had already initiated broad changes and updates across most of the areas identified, while acknowledging capacity gaps in internal controls and IT. Early audit findings showed less than 1% of potential waste, which is far less than the 5% estimate provided by the Association of Certified Fraud Examiners.

Using the color key below, please review our progress in many of the areas.

GREEN – Completed

YELLOW – In progress

ORANGE – Just starting


HR	Benchmarking	As part of the existing reorganization plan, all positions are being audited for documented qualification and certification verification, and new roles are being reviewed by a hiring manager. The targeted completion date is July 31, 2026.
	I-9 Recordkeeping	The district has been in the process of conducting an I-9 inventory with a targeted due date of May 31, 2026. Part of the work will be securing the I-9 storage room with proper access controls.
	Maintaining Institutional Knowledge	The district underwent a massive layoff during the prior superintendent's tenure — more than 1,000 positions were eliminated. We have aggressively worked to rebuild the internal structure and historical knowledge, including the redevelopment of structures and processes proven effective.
	Organizational Charts	A new organizational chart has been developed and is in use district-wide.
	Processes, e.g., Data Quality, Employee File Maintenance, I-9	The district hired a seasoned human resources veteran in July 2025 to lead this important area. The chief is in the process of shifting the department culture and introducing processes and safeguards.
	State Board of Education Reporting	State law requires the director of schools (or designee) to report educator suspensions, dismissals, and resignations tied to misconduct to the State Board within 30 days. This is regulatory guidance, not a criminal statute. During substantially all of FY2025, these reports were not submitted because the prior superintendent declined to sign the required forms. The current superintendent has submitted all forms in compliance with state reporting requirements.
	Succession Planning	A succession plan is under development by the chief of human resources.

Contracts	Authorization	A draft RACI (Responsible, Accountable, Consulted, Informed) matrix has been developed to document authorization roles across procurement and contracts/legal. This process is outlined in the district's modernization plan.
	Monitoring	To ensure more accurate monitoring and accountability of contracts, the district has executed new rules regarding assigned owners of every contract. Further checks and balances have been proposed as part of the modernization plan.
	Quality Assurance	The district is developing a centralized review workflow.
	Requests for Qualifications	Leadership has reviewed the guidance provided by the auditing firm to develop a consolidated end-to-end professional services contracting procedure that integrates procurement, legal, contract administration, and accounts payable requirements. Furthermore, we agree with the guidance to draft and post an RFP for independent compliance co-sourcing.
	Single Source/Sole Source Procurement	The district is in the process of adopting a sole/single source standard operating procedure. As recommended, this will call for all professional services contracts — regardless of source structure — to adhere to procurement requirements: requisition, budget check, purchase order, and vendor registration before services begin.
	Vendor Record-Keeping	The district agrees with the audit recommendation to complete a separate audit of all Contract Advantage vendor and contract classifications to correct inaccuracies and implement validation controls at intake to prevent future errors.

Accounts Payable	Payment Processing	An updated payment processing procedure has been completed and will be part of all standard operating procedures.
	Payroll Processing	A standardized Payroll Change Authorization Form has been implemented. The APECS system includes an audit trail, and second-level approval and documented business justification is required before any manual check is issued.
	Procuring Equipment	In alignment with Policy #2006, the district has an existing process for all equipment purchases to follow, including requisition, budget verification, purchase order, and vendor registration before services or goods are received. Further, the department is updating warehouse storage guidelines to include physical separation and labeling of federal grant-funded equipment with grant identifiers. Warehouse staff will be trained on grant compliance. This is expected to be completed by May 2026.
	Purchases	Complete supporting documentation (signed invoice, business purpose, approvals) is already required in APECS for all purchase types — ACH, warrants, vCards, and check requests — before payment release.

Internal Controls	Conflicts of Interest & Ethics/Fraud Hotline	The district acknowledges gaps in these processes and is currently reviewing the audit's recommendations to execute accordingly.
	Formalized Processes & Procedures	The current audit charter is from 2021. An in-progress update was paused when the previous superintendent changed the reporting and organizational structure of the Internal Audit Department. The Internal Audit team will provide an updated audit charter to the current superintendent and Board for review and approval in the coming months. The Office of the Chief of Staff has begun the initial review of standard operating procedures (SOPs) in partnership with the Project Management (PM) team and the applicable Offices of Primary Responsibility (OPRs). Each department will schedule dedicated time with the PM team and the Office of the Chief of Staff to ensure all current SOPs are added to the system. SOPs will be updated to include sufficient detail, including screenshots where applicable, so that a new employee can perform the role immediately upon gaining system access. The Office of the Chief of Staff, PM team, and OPRs will also collaborate to develop visual workflows to complement the updated SOPs. This is ongoing work, with SOPs reviewed annually at minimum and updated as needed to ensure continued efficiency and operational reliability.
	Internal Audit Manual	The development of an internal audit manual is underway.
	Internal Audit Team	The internal audit team has participated in the following trainings since December 2025: - Virtual Bootcamp, Dec. 8-12, 2025 - Internal Controls Workshop, Feb. 18-19, 2026 - Conducting Performance Audits, March 3-5, 2026 - Yellowbook Training - Audit Interviewing, March 26, 2026 Training will be continuous throughout the year, and the department will formally adopt the Institute of Internal Auditors (IIA) standards. Additionally, the Superintendent is committed to investing in two performance auditors and training for the Internal Audit Department to have the capacity to define and evaluate the district’s audit universe, conduct formal risk assessments, and develop an annual audit plan.
	Policy Management	The Policy team will identify the proper parties for individual policy management and responsibility and propose amendments as necessary and practical to ensure that the appropriate policy management personnel are identified.
	Record Retention	The district will establish a universal retention schedule, e.g., seven years as a default, with department-specific exceptions, centralized at the district level. This work is on track for completion by April 15, 2026.
	School Funds Audit	The district is following the Comptroller’s school audit requirement for Internal School Funds. According to the Internal School Funds Manual issued by the Division of Local Government Audit, Internal Audit (IA) staff may perform audits other than the annual audit. The annual audit is performed by the external CPA firm Watkins Uiberall, which issues the opinion on the district’s financial statements, however Watkins Uibierall relies on the work of the district’s Internal Audit staff for performing the compliance audits relative to internal school funds. Statement on Auditing Standards 128 (SAS 128) allows external auditors to rely on the work of an internal audit function of an organization when the external firm is engaged to perform financial audits. Watkins Uibierall complies with SAS 128 by providing direction to the district’s Internal Audit Department regarding internal school fund audits by reviewing and agreeing to the audit program used to document audit procedures. Additionally, Watkins Uiberall reviews all workpapers related to internal school fund audits to ensure audit quality.

Funding	Budget Revisions & Transfers	The district currently uses APECS, based on its ability to effectively manage all budget processes.
	Federal & State (Charter & Head Start)	The district agrees with the recommendation to develop an updated travel policy, journal entry standards, and standard operating procedures for Title I and ESSER, along with the recommendation to require a grant manager to co-sign on all federally funded documents. Further, MSCS will issue a district-wide directive requiring specific school location codes for all federal grant expenditures. The controller will audit quarterly. Head Start documentation will migrate into the APECS centralized repository within 90 days of receipt, and all charter school disbursements will be redirected through the charter office within 30 days of receipt.
	Financial Transactions & Controls	The district is executing the recommendation to centralize journal entry processes to provide the Finance Department read-access to all departmental supporting documentation before approving entries. Further, the district will begin the pre-payment documentation checklist for all transaction types in APECS and initiate ERP assessment to evaluate integration of payroll, inventory, and finance systems. Findings will be presented to the Board.
	Board Discretionary Budgets	The district previously drafted a formal Board Member discretionary budget policy covering allowable uses, approval process, and required documentation. This policy was presented and approved by the Board.

Governance	Policy Management	The district conducts a comprehensive review of all policies every two years in accordance with State statute. The last review cycle began in 2024 and was completed in 2025. On March 25, 2025, the Board adopted a resolution formally acknowledging completion of the biennial review. The Policy Office also maintains a policy calendar identifying upcoming policies for review and Board approval. Revision dates on policies indicate when the policy text was revised, not the most recent review date. The Policy Office will update all policies to include the last review date as well.

IT	Cybersecurity Controls	As technology continues to change rapidly, and security needs expand, we acknowledge gaps in our IT infrastructure and capacity. We are seeking external guidance to bolster this department.

Whitehaven STEM Center	Agreement	The Whitehaven STEM Center construction is complete, and the building has been handed over to the district. There is no agreement to be executed. For current and future facility-related donations, MSCS will contract with the donating party to ensure the project is fully planned out and executed per contract terms. We cannot speak to why this did not happen with the Whitehaven STEM Center, as none of the members of that district construction team are still with the district.
	Building Size	The increasing cost of materials and labor at the time of construction — versus when the project was initiated — accounts for the discrepancy in square footage. Processes and documentation requirements have been strengthened since the time of the STEM project and are in effect.
	Funding	The building was funded through donations and built by a private, third party. As such, there were no district requisitions, budget verifications, purchase orders, or vendor registrations necessary. The district did not receive the money, only the completed new building. This was a private party donating a building to the district. The private party had full control over its procurement processes with the money it raised without district assistance. The district encourages small business participation and competitive bidding in all third-party projects. The STEM Center funding flowed through School Seed, not the district. The district functioned as another donating party, and the Board approved any district funds contributed to the project. Additional building work or needs, such as IT, security, and furnishings, will be procured through the district process by the departments in charge of those areas. The utility and operating expenses will be paid by the district just as they are for all schools, as the STEM Center is now simply another part of the Whitehaven High School campus.

Operational Modernization & Excellence Plan

Memphis-Shelby County Schools launched its Operational Modernization & Excellence Plan in response to longstanding gaps in internal controls, documentation integrity, and financial governance that required urgent, structured remediation.

The plan establishes seven pillars of modernization , spanning procurement, HR file compliance, payroll controls, digital transformation, program efficiency, independent compliance co-sourcing, and a compliance calendar, to ensure the district operates with the transparency, accountability, and stewardship that students, families, and the public deserve.

By assigning pillar leads, defining clear execution steps, and anchoring the work to recognized frameworks like COSO, the plan moves the district from reactive problem-solving to a sustainable, institutionalized compliance infrastructure.

The Operational Modernization & Excellence Plan Dashboard was developed to give Superintendent-level leadership real-time visibility into the progress and health of each reform pillar.

Rather than relying on periodic reports or anecdotal updates, the dashboard consolidates key metrics, from contract repository completion rates and HR file integrity percentages to payroll documentation compliance and RFP status, into a single, structured oversight tool.

Each dashboard section maps directly to a corresponding pillar in the modernization plan, ensuring that accountability is not only assigned but actively tracked, and that the Superintendent and the Board can identify risks early, monitor remediation timelines, and confirm that the district’s operational foundations are being strengthened in real time.

https://www.scsk12.org/district-transparency/test