COLORADO Department of Education Commissioner of Education 201 East Colfax Avenue Denver, CO 80203-1799 Dr. Elizabeth Celania-Fagen, Superintendent Douglas County School District 620 Wilcox Street Castle Rock, CO 80104 June 23, 2015 Dear Dr. Fagen: This letter is in response to the Douglas County School District's June 5, 2015 appeal of the pupil count audit findings. The audit, dated May 7, 2015 reflects adjustments to the October pupil counts for 2012 and 2013. You have asked me to review the appeal through various factors indicated in your letter. As I have reviewed this appeal, I have incorporated the following items into my decision: 1. Budget Reductions and Impacts on Full-Time Funding The district, along with every other district in the state had to absorb tremendous budget reductions during the time period of the audit through legislative actions. The district, along with all other districts, made decisions and choices as to how to absorb the reductions and how to continue to provide services to the students within the district to provide educational opportunities. Within Douglas County, the district chose to redo high school schedules and class period offerings to stay within the district?s available resources. However, errors were made in the calculations for the determination of full-time funding as high school schedules were set. The evidence that we have received indicate the district was aware of the potential shortage in the scheduled time, however did not correct the problem until the 2014-15 school year. In order to be eligible to be counted for full-time funding, a student must meet the criteria established in state law and state board rule. A minimum of 360 hours of pupil-teacher contact time in the first semester must be demonstrated on student schedules. The district?s appeal asks for the department to provide proportional funding for students that did not have the full 360 hours of scheduled time. There is no provision in state law to allow for proportional funding - students are either considered full-time or part-time. As the appeal has pointed out, all districts have absorbed budget reductions through the economic downturn and have made significant changes to educational delivery models and districts have managed to maintain the integrity of their full-time schedules. In consideration of the fiscal impact to the district, as the department reviewed the high school schedules, an alternative calculation was developed, consistent with state board rules, which allowed an additional 236 students to be considered full-time which was incorporated into the original audit. If the traditional calculation was applied to this audit, the district liability would have increased by 201 East Colfax Avenue, Denver, CO 80203-1799 303.866.6600 303.830.0793 Robert K. Hammond, Commissioner of Education Keith Owen Deputy Commissioner approximately $737,000, resulting in a total audit liability of over $5.3 million. In addition, the department applied a global approach to passing time. This global approach assigned more time for some students than was actually supported by their individual schedules. Therefore, an undetermined number of students were considered to be full-time when, in fact, the individual student schedules did not meet the required minimum of 360 hours. Passing time accounted for approximately 28 hours in a student?s schedule. 2. Appeals not related to minutes a. The information outlined in the appeal letter and student specific documentation provided as part of the appeal has been reviewed and the department has made adjustments equating to a reduction in findings of 5.5 full-time equivalent (FTE). The adjustments made are outlined below. i. Castle View High School - No changes were made to these exceptions. The district did not provide valid evidence in order to make any adjustments. ii. Students receiving expelled services - No changes were made to these exceptions. The district did not provide valid evidence in order to make any adjustments. Students on work study - The district provided sufficient evidence to reduce the findings by 2.5 FTE. iv. Early Access students The district provided sufficient evidence to reduce the findings by 1.5 FTE. v. Students receiving special education services The district provided sufficient evidence that supports full-time funding for 1.0 FTE therefore this exception was removed. vi. Retained Kindergarten students - The district provided documentation related to one retained kindergarten student representing 0.5 FTE. This exception was removed. Total FTE FTE FTE Adjustment Adjustment for Adjustments Category of Student for 2012-13 2013-14 Castle View High School -0- -0- -0- Expelled Students -0- -0- -0- Work Study Students 1.0 1.5 2.5 Early Access 1.0 .5 1.5 Special Education 1.0 -0- 1.0 Retained Kindergarten -O- .5 .5 Total Adjustments 3.0 2.5 5.5 201 East Colfax Avenue, Denver, CO 80203-1799 303.866.6600 303.830.0793 Robert K. Hammond, Commissioner of Education Keith Owen Deputy Commissioner I b. State Share vs. Local Share i. The audit requirement to return funding to the state is only for the state share of the district's total program funding. The district is not required to return any local funds to the state. Once the total program funding has been calculated, the local share is applied first, and then remainder is funded by the state. In the case of a lower total program due to fewer students, the same amount of local share is still applied first, and the remainder is a lower amount of state share. Total Program - Local Share State Share The amount of funding to return to the state is only the state share portion. This is illustrated below and was included in the original audit report, schedules A1 for FY2012-13 and A2 for FY2013-14: Original Schedule A1 - 2012-13 Item District Original Audit Difference Funded Count 61,199.1 60,812.0 (387.1) Total Program $380,857,327.34 $378,465,672.25 Property Tax (Local) 116,457,417.64 116,457,417.64 -0- Specific Ownership Tax (Local) 8,592,959.72 8,592,959.72 -0- State Share $255,806,949.98 . I. .1 $253,415,294.89 9., Schedule 2- 2013-14 Funded Count 62,610.2 62,318.5 (291.7) Total Program $400,450,127.87 $398,601,701.06 Property Tax (Local) 119,932,501.52 -0- Specific Ownership Tax (Local) 9,669,990.07 9,669,990.07 -0- State Share $270,847,636. 28 $268,999,209.47 As you can see by the tables above, there are no local funds being requested as part of the pupil count audit. Timing of audit As it states in rule 1 CCR 301-39801, districts are required to retain documentation of pupil counts for a period of up to five years. Since the audit exceptions resulted from a district initiated change, rather than any change in audit requirements or practices, it is important the district remains in compliance with pupil count requirements. The department provides annual training on pupil count submissions and associated rules. The district has participated in these trainings, and we encourage continued participation. We have noted that the district has made necessary changes to the schedules for the October 2014 pupil count. Substantial compliance See discussion above - there is no provision within the School Finance Act to fund students on a proportional amount basis. Students are considered either full-time and funded as one full-time pupil or part-time and funded as one-half pupil. Full-time funding is based upon a student having a schedule for 360 hours, and part-time funding is available for students with schedules greater than 90 hours but less than 360 hours in the first semester. 201 East Colfax Avenue, Denver, CO 80203-1799 303.866.6600 303.830.0793 Robert K. Hammond, Commissioner of Education Keith Owen Deputy Commissioner However, I understand the precise calculations that were used to determine full-time vs. part- time schedules and I am utilizing my discretion to allow for variance of the scheduled numbers of hours in the following manner above and beyond what was discussed above: i. Minutes per day requirement is adjusted from 244.16 minutes per day to 244, therefore allowing full-time funding for an additional 79 students. This reduces the audit exceptions by 39.5 FTE. ii. Round the scheduled hour requirement down to 357 scheduled hours which allows full- time funding for an additional 32 students. This reduces the audit exceptions by 16 While i believe that all of the audit findings are correct and appropriate under statutes and regulations, I also understand the significant financial impact that these findings will have on the district. Therefore, I am exercising discretion by directing the School Finance and Operations Division to reduce your audit findings by $379,632.85 to $4,241,428.96. This amount is determined upon review of all information and is summarized below: 2012-13 2013-14 Number of Number of Reduced Reduced Audit Audit Total Reduced Finding Findings Findings Findings Not related to minutes 3.0 2.5 5.5 Reduction of minutes to 244 29.0 10.5 39.5 Hours rounded to 357 hours 13.0 3.0 16.0 Total FTE Reduction 45.0 16.0 61.0 Total Amount of Reduction $278,188.91 $101,443.94 5 379,632.85 Original Audit Findings in Total $4,621,061.81 Less Amount of Reduction (379,632.85) Revised Audit Finding Total 4,241,428.96 This reduction of $379,632.85 along with the alternative calculation for time that was incorporated into the original audit reduces the district?s liability by over $1.1 million to just over $4.2 million. Please note that revised Schedules A1 and A2 for both FY2012-13 and FY2013-14 are attached including the final invoice with a revised settlement date to determine interest accruals. Per Rule 1 CCR ?The Commissioner?s ruling shall be final, and no additional administrative appeals shall be provided.? 201 East Colfax Avenue, Denver, CO 30203-1799 303.866.6600 303.830.0793 Robert K. Hammond, Commissioner of Education Keith Owen Deputy Commissioner Please contact Mary Christel at 303-866-6818 - Christel m@cde.state.co.us for assistance in making payments. She will provide you with payment options for this pupil count audit. Sincerely, mM/ Mex/J Robert K. Hammond Commissioner of Education Enclosures CC: School Finance and Operations Division 201 East Colfax Avenue, Denver, CO 80203-1799 303.866.6600 303.830.0793 Robert K. Hammond, Commissioner of Education i Keith Owen Deputy Commissioner COLORADO DEPARTMENT of EDUCATION renames RE?ti' ?9 escrigtion FC1. FY13 October FTE Count (minus on?Iine)- enter line V5 FCZ. FY12 October FTE Count - enter line V13 FC3. FY11 October FTE Count - enter line V14 FC4. FY10 October FTE Count - enter line V15 FC4.1. FY09 October FTE Count - enter line V15.1 F05. AVERAGED FUNDED PUPIL COUNT enter the greater of line FC1 or FC5.1. FY13 Full Day Kindergarten Factor FC6. FY13 CPP Pupil Count - enter line V17 F0631. FY13 Chatter Institute CPP Pupil Count - enter line V20.1 F065. FY13 CHARTER INSTITUTE PUPIL COUNT - enter line V19 F066. FY13 Charter Institute Full Day Kindergarten Factor FC7. FY13 FUNDED PUPIL COUNT - enter line FC5. plus F051. plus line F075. FY13 ASCENT Pupil Count - enter line FC4.1 FCT.6. FY13 CHARTER INSTITUTE ASCENT Pupil Count - enter line V206 F08. FY13 On-line Multi?District Pupil Count - enter line V4 FCB.5. FY13 CHARTER INSTITUTE ONLINE PUPIL COUNT - enter line V20 FCQ. TOTAL FUNDED PUPIL COUNT - enter line FC7 plus line FCB plus CD AR4. Projected K-12 free lunch count using 1-8 percent - AR5. Free Lunch (grades K-12) Count - enter line V7 plus V18 (ELL AR6. FY13 At-Risk Pupil Count TF 1. Formula Funding without At-risk - enter line PPQ TF2. Formula At-risk Funding enter line AR19 TF3. Formula Funding - enter line TF1 plus line TF2 TF4. On-Line Formula Funding - enter line 0L3 TF5. Total Formula Funding (including on-Iine funding) - enter line TF3 TF6. Minimum Formula Funding - enter line MF3 TF10. TABOR Formula Funding - enter line T84 TF11. TOTAL FORMULA FUNDING TP2. Total Funding Beyond TABOR Formula - enter line AF6 GT1. TOTAL PROGRAM FUNDING - enter line TP3 V31. FY13 Assessed Valuation ML6. EQUALIZED MILL LEVY (FINAL) GT2. PROPERTY TAX REVENUES - enter line ML6 times line V31 GT3. SPECIFIC OWNERSHIP TAX enter line V30 GT4. STATE SHARE GT6. TOTAL PROGRAM PER-PUPIL FUNDING GT7. NEGATIVE FACTOR GT7.1. TOTAL PROGRAM GT7.2. PROPERTY TAXES G173. SPECIFIC OWNERSHIP TAXES GT7.4. STATE SHARE GT7.5. REQUIRED CATEGORICAL BUYOUT FROM TOTAL PROGRAM GT7.6. PER PUPIL FUNDING AFTER NEGATIVE FACTOR GT8. Adjusted district Ira-school per pupil funding GT9. District On?Iine per pupil funding GT10. Charter School Institute Total Program Funding GT11. ADJUSTED TOTAL PROGRAM FUNDING (GT1 plus GT12. PROPERTY TAX REVENUES - enter line GT2 GT13. SPECIFIC OWNERSHIP TAX - enter line GT3 GT14. ADJUSTED STATE SHARE 57.5695 56,063.5 54,517.0 53211.5 51,738.5 57,569.5 376.6 117.5 0.0 0.0 0.0 58,0636 0.0 0.0 3,135.5 0.0 61.1991 6,021.5 5,693.5 6,021.5 $426,502,438.15 $5,307,664.90 $431.810,103.05 $22.092.733.00 $453,902.836.05 $447,398,732.19 $452,624,500.81 $452,624,500.81 $1,278,335.24 $453,902,836.05 $4,577,728.681 0.025440 $116,457,417.64 $8,592,959.72 $328,852,458.69 $7,416.82 $380,857,327.35 $116,457.417.64 $8,592,959.72 $255,806,949.99 $0.00 $6,223.25 $6,240.05 $5,912.10 $0.00 $380,857,327.35 $116,457,417.64 $8,592,959.72 $255,806,949.99 BiStrict PUBLIC SCHOOL FINANCE ACT OF 1994 Page 1 of 1 06/22/2015 2012-2013 AUDITED PUPIL COUNT CALCULATIONS Schedule: A1 Audit 57232.0 56.0635 54.5170 53.2115 51.7385 57232.0 376.6 117.5 0.0 0.0 0.0 57.7251 0.0 0.0 3,131.0 0.0 60,8571 6,012.4 5,686.5 6,012.4 $424,023,353.61 $5,299,643.69 $429,322,997.30 $22,061 ,026.00 $451 ,384,023.30 $444,894,895.06 $450,158.345.71 $450,158,345.71 $1,225,677.59 $451 .384,023.30 $4,577,728,681 0.025440 $116,457,417.64 $8,592,959.72 $326,333,645.94 $7,417.11 $378,743,861.17 $116,457,417.64 $8,592,959.72 $253,693,483.81 $0.00 $6,223.50 $6,240.38 $5,912.10 $0.00 $378,743,861.17 $116,457,417.64 $8,592,959.72 $253,693,483.81 Difference: 337.5 0.0 0.0 0.0 0.0 337.5 0.0 0.0 0.0 0.0 0.0 337.5 0.0 0.0 4.5 0.0 342.0 9.1 7.0 9.1 $2,479,084.54 $8,021.21 $2,487,105.75 $31,707.00 $2,518.812.75 $2,503,837.13 $2,466,155.10 $2,466,155.10 $52,657.65 $2,518,812.75 $0 0.000000 $0.00 $0.00 $2,518,812.75 -$0.29 $2,113,466.18 $0.00 $0.00 $2,113,466.18 $0.00 -$0.25 -$0.33 $0.00 $0.00 $2,113,466.18 $0.00 $0.00 $2,113,466.18 PUBLIC SCHOOL ACT OF 1994 Page 1 0? COLORADO 05/22/2015 01 11PM DEPARTMENT of 2012-2013 AUDITED PUPIL COUNT DATA EDUCATION Audit Part Audi! Audit FTE Audit FTE . Audit Online Time FTE Not-E159 Other-E99 Count . FTE Count SP ED PK 000 550.0 250.0 .0 .0 250.0 00? 235.0 117.5 .0 .0 117.5 KINDERGARTEN 0051007 4,710.0 2,353.5 3.0 0 2,353.5 ?010 4,917.0 335.0" 1.0 0 4,551.0 GRADE 2 020 5,055.0 24.5 2.0 .0 5,039.5 5,123.0 26.5 .0 .0 5,095.5 GRADE 4 040 5,238.0 22.5 .0 5.2155 5 050 5,133.0 23.0 1.0 GRADE 5 050 5,202.0 15.5 1.0 . GRADE 7 57.0? 5,202.0 22.0 .0 . 5,150.0 GRADE 5 050 4,905.0 17.5 3.0 . 4,557.5 0 0 5,109.0 0 0 0 090 4,457.0 5.5 3.0 .0 4,455.5 0 0 0 5,132.5 GRADE 10 100 4,425.0 5.0 9.0 . 4,411.0 GRADE 11' '110 4,229.0 45.5 5.0 . 4,174.5 5 GRADE 12 120 4,392.0 279.0 19.0 . 4,094.0 4,370.5 275.5 293.5 295.0 1.5 251 251 0 TOTAE 53,507.13 3,275.5 50.0 . 60.4805 COLORADO DEPARTMENT of EDUCATION is'tricti'N?ar'?? ,escription FC1. FY14 October FTE Count (minus on-Iine)- enter line V5 FC2. FY13 October FTE Count - enter line V13 FC3. FY12 October FTE Count - enter line V14 FC4. FY11 October FTE Count enter line V15 FC4.1. FY10 October FTE Count - enter line V15.1 FC5. AVERAGED FUNDED PUPIL COUNT - enter the greater of line or FC5.1. FY14 Full Day Kindergarten Factor FCS. FY14 CPP Pupil Count - enter line V17 F061. FY14 Charter Institute CPP Pupil Count - enter line V201 FC6.5. FY14 CHARTER INSTITUTE PUPIL COUNT - enter line V19 F066. FY14 Charter Institute Full Day Kindergarten Factor FC7. FY14 FUNDED PUPIL COUNT - enter line FC5. plus F051, plus line FCT.5. FY14 ASCENT Pupil Count - enter line FC4.1 FC7.6. FY14 CHARTER INSTITUTE ASCENT Pupil Count - enter line V206 FC8. FY14 On-line Multi-District Pupil Count - enter line V4 FCB.5. FY14 CHARTER INSTITUTE ONLINE PUPIL COUNT - enter line V20 FCQ. TOTAL FUNDED PUPIL COUNT - enter line FCT plus line FC8 plus CD AR4. Projected free lunch count using 1-8 percent - AR5. Free Lunch (grades K-12) Count - enter line V7 plus V18 (ELL AR6. FY14 At-Risk Pupil Count TF1. Formula Funding without At?risk - enter line PPQ TF2. Formula At-risk Funding - enter line AR19 TF3. Formula Funding - enter line TF1 plus line TF2 TF4. On-Line Formula Funding - enter line 0L3 TF5. Total Formula Funding (including on-Iine funding) - enter line TF3 TF6. Minimum Formula Funding - enter line MF3 TF10. TABOR Formula Funding - enter line T84 TF11. TOTAL FORMULA FUNDING TP2. Total Funding Beyond TABOR Formula enter line AFB GT1. TOTAL PROGRAM FUNDING - enter line TP3 V31. FY14 Assessed Valuation ML6. EQUALIZED MILL LEW (FINAL) GT2. PROPERTY TAX REVENUES - enter line ML6 times line V31 GT3. SPECIFIC OWNERSHIP TAX enter line V30 GT4. STATE SHARE GT6. TOTAL PROGRAM PER-PUPIL FUNDING GT7. NEGATIVE FACTOR GT7.1. TOTAL PROGRAM GT7.2. PROPERTY TAXES GT7.3. SPECIFIC OWNERSHIP TAXES GT7.4. STATE SHARE GT7.5. REQUIRED CATEGORICAL BUYOUT FROM TOTAL PROGRAM GT7.6. PER PUPIL FUNDING AFTER NEGATIVE FACTOR GT8. Adjusted district In-school per pupil funding GT9. District On-Iine per pupil funding GT10. Charter School Institute Total Program Funding GT11. DISTRICTS ADJUSTED TOTAL PROGRAM FUNDING (GT1 plus GT12. PROPERTY TAX REVENUES - enter line GT2 GT13. SPECIFIC OWNERSHIP TAX - enter line GT3 GT14. ADJUSTED STATE SHARE 58,9760 57,569.5 56,063.5 54,517.0 53,211.5 58,976.0 369.2 116.5 0.0 0.0 0.0 59.4617 0.0 0.0 3,148.5 0.0 62,6102 6,440.6 6,044.5 6,440.6 $445,070,61648 $5,784,944.22 $450,855,560.70 $22.606,230.00 $473,461 .790.70 $466.318.354.65 $473.012.145.45 $473,012,145.45 $449,645.25 $473,461 .790.70 $4,714,327.890 0.025440 $119,932,501.52 $9,669,990.07 $343,859.299.1 1 $7,562.06 $400,450,127.88 $119,932,501.52 $9,669,990.07 $270,847,636.29 $0.00 $6,395.92 $6,413.03 $6,072.79 $0.00 $400,450,127.88 $119,932,501.52 $9,669,990.07 $270,847,63629 District- PUBLIC SCHOOL FINANCE ACT OF 1994 Page 1 of 1 06/22/2015 2013-2014 AUDITED PUPIL COUNT CALCULATIONS Schedule: A2 58.7005 57,232.0 56.0635 54.5170 53.2115 58.7005 369.0 116.5 0.0 0.0 0.0 59,1860 0.0 0.0 3,148.5 0.0 62,3345 6,438.5 6,041.5 6,438.5 $443,007,002.95 $5,783,058.00 $448.790.060.95 $22,606.230.00 $471 ,396.290.95 $464,261 ,039.90 $470,928.951.51 $470,928,951 .51 $467,339.44 $471 ,396.290.95 $4,714,327.890 0.025440 $119,932,501.52 $9,669,990.07 $341 ,793,799.36 $7,562.37 $398,703,145.01 $119,932,501 .52 $9,669,990.07 $269,100.653.42 $0.00 $6,396.19 $6,413.39 $6,072.79 $0.00 $398,703,145.01 $119,932.501.52 $9,669,990.07 $269,100,653.42 Au?it 'oirrenenc? 275.5 337.5 0.0 0.0 0.0 275.5 0.2 0.0 0.0 0.0 0.0 275.7 0.0 0.0 0.0 0.0 275.7 2.1 3.0 2.1 $2,063,613.53 $1,886.22 $2,065,499.75 $0.00 $2,065,499.75 $2,057,314.75 $2,083,193.94 $2,083,193.94 $2,065,499.75 $0 0.000000 $0.00 $0.00 $2,065,499.75 -$0.31 $1,746,982.87 $0.00 $0.00 $1 .746.982.87 $0.00 -$0.27 -$0.36 $0.00 $0.00 $1,746,982.87 $0.00 $0.00 $1,746,982.87 PUB IC SCHOOL FINANCE ACT OF1994 Page 1 DH COLORADO 0512212015 01 12PM DEPARTMENT of 2013-2014 AUDITED PUPIL COUNT DATA EDUCATION Audit Audit Part Audit FTE Audit FTE Audit On?ne Membership Time Not-Big Other-Eng Count . FTE Count .0 0 180.0 SP ED PK 000 551.0 330.5 .0 .0 330.5 Ci??b PK 4 .004 a 233.0 115.5 .0 .0 115.5 KINDERGARTEN 0051007 4,592.0 2,255.5 .0 .0 2.3055 GRADE-1 4 5,001.0 43.0 1.0 .0 4,957.0 299.0 252.0 297.0 010? GRADE 2 020 5,102.0 41.0 1.0 .0 5,050.0 0 5,211.0 5:21?: 030 5,243.0 32.0 .0 . GRADE 4 040 5,345.0 35.5 .0 .0 5,305.5 252.0 0?30 5,335.0 22.5 .0 . 5,313.5 259.0 GRADE 5 050 5,322.0 29.0 4.0 . 5,259.0 5,259.0 .0 255.0 GRADE 7 A A 070 5.2730 27.0 3.0 . 5,245.0 230.5 GRADE 5 050 5,243.0 19.5 3.0 . 5,220.5 277.0 151.5 0 0 0 0 GRADE9 4,720.0 7.5 3.0 .0 4,705.5 0 151479 505 400 GRADE 10 100 4,445.0 5.0 5.0 . 4,433.0 GRAEJE 11 110' 4,375.0 33.0 4.0 . 4,335.0 2:5 150.0 4,125.0 4,355.0 237.0 254.5 GRADE 12 120 4,400.0 249.0 23.0 . 3,148.5 308 309 31 1 61.9655 5,991 7:0ng 55,2940 3,250.5 45.0 . Colorado Department of Education A 0 School Finance Division Department of Education 201 E. Colfax Ave., Room 206 .- School Finance Denver, CO 80203 REVISED INVOICE BILL TO: Invoice Date: June 23, 2015 Dr. Elizabeth Celania-Fagen Douglas County School District 620 Wilcox Street Castle Rock, CO 80104 RE: Final bill for funds clue to the Department based on an overpayment of funds that were greater than the district was entitled as evidenced by the Final Audit Report Appeal Letter dated June 23, 2015. Revhed Appeal Amount Due to Program Fiscal Year Original Due Reduction CDE State Equalization (Source 3210; Grant 0000) 2012-2013 2,391,655.09 278,188.91 $2,113,466.18 2013-2014 1,848,426.81 101,443.94 1,746,982.87 Transportation (Source 3200; Grant 3160) 2011-2012 360,204.72 360,204.72 2012-2013 20,775.19 20,775.19 Total 4,621,061.81 379,632.85 $4,241,428.96 Payments should be mailed to the following address: For questions concerning payment, please contact: Colorado Department of Education Mary Christel School Finance Division christelmm@cde.state.co.us 201 E. Colfax Ave., Room 206 (303) 866?6818 Denver, CO 80203 In accordance with Section audits that begin on or afterJuly 1, 2007 shall not recover an interest fee for the period that is equal to the number of years and any fraction of a year between the settlement date of the current audit and the settlement date of the immediately preceding audit. The settlement date of the proceeding audit was July 24, 2013. Interest will begin accruing on the remaining balance as of the settlement period date of May 23, 2017.