Information on OLAG Audit

Tooele County School District (TCSD) appreciates the work of the Office of the Legislative Auditor General (OLAG) and views the systematic performance audit as an important opportunity to reflect, learn, and grow. Audits are a routine and essential part of public education, serving as a system of checks and balances that help ensure our policies and practices align with the highest standards of accountability and student safety.

About the OLAG Audit

The audit conducted for TCSD is part of OLAG’s systematic performance audit initiative, which is being carried out across all school districts in the state of Utah. Similar audits have already been completed in districts such as Salt Lake City, Park City, Rich, and Alpine, with additional districts scheduled in the coming years. The audit for Tooele County School District spanned approximately nine months, with findings released publicly on June 18, 2025.

While our superintendent met with auditors during the process and a very limited number of district personnel were given access to preliminary findings under strict confidentiality, the broader district leadership and community, including the Board of Education, first saw the audit findings when they were made public. Some members of the media received early access 24 hours prior to the public release, but the district was not granted access with the select few who were aware not permitted to review or discuss the report until it became publicly available.

We will continue to update this page as we receive feedback and have the opportunity to review the findings and recommendations from the audit.

Our Commitment to Improvement

Even without knowing the full scope of the audit’s conclusions in advance, TCSD used this time to engage in self-reflection. We examined our current practices and identified areas where we can strengthen our efforts, not only in adhering to policy, but in how we educate and support our employees and volunteers in understanding and applying those policies effectively. Some of the steps we’ve already taken this year, such as policy updates, staff training, and process improvements, were initiated based on internal observations and may or may not be directly addressed in the audit. Regardless of where suggestions comes from, we are committed to addressing audit findings and recommendations with integrity, responsiveness, and a focus on continuous improvement.

We are also learning from the experiences of other districts, including the recent DOJ investigation into Davis School District, and are taking deliberate steps to avoid similar challenges. While no system can prevent every incident, we believe that a strong culture of education, accountability, and awareness can make a meaningful difference.

What is the OLAG audit?

The Office of the Legislative Auditor General (OLAG) is conducting a Systematic Performance Audit of every school district in Utah. These audits are designed to evaluate how districts operate and ensure alignment with state laws, policies, and best practices.

Why was TCSD audited?

TCSD was selected as part of OLAG’s statewide initiative. Similar audits have already been completed in other districts such as Salt Lake City, Park City, Rich, and Alpine. The audit for TCSD lasted approximately nine months and concluded with a public report released on June 18, 2025.

When did TCSD receive the audit findings?

The district received the findings at the same time as the public. While a few individuals were involved in confidential meetings during the process, the full report was not shared with district leadership or the Board of Education until its public release.

What has TCSD done in response?

Even before receiving the final report, TCSD conducted an internal review and began implementing improvements. These include:

• Selecting a districtwide communication platform for all staff-student interactions.
• Updating mandatory reporting policies.
• Providing Title IX and discrimination training.
• Supporting student-led initiatives to promote inclusivity.

The district will continue to provide updates here on our website regarding the audit findings as well as any implementations and improvements TCSD has made as a result of the audit and internal findings.

Where can I read the full audit report?

The full report is available on the Utah Legislative Auditor General’s website and will be linked on the TCSD audit information page.

How can I share feedback or ask questions?

Immediately below this tab is a dedicated contact form to gather community feedback and questions. This helps us respond efficiently and keep communication organized.

TCSD Performance Audit Recommendations

Timeline: July 2025 – June 2026 Status Key (text‑only):

• Initiated

• Continued Implementation

• Complete

• Target Completion

• Ongoing Initiative

Chapter 1

1.1 Assistant Superintendent for Academics Assigned to: Mark Ernst

1.2 Adjust Policy 2002 Assigned to: Melissa Rich

1.3 Assistant Superintendent to Set Goals Assigned to: Cody Reutzel

1.4 Plan to Track Goals Assigned to: Melissa Rich

Chapter 2

2.1 Board Focus on Student Achievement Assigned to: Melissa Rich

2.2 Standing Board Agenda Item Assigned to: Melissa Rich

2.3 Job Description for Policy Director Assigned to: Mark Ernst

2.4 HR System for Consistency Assigned to: Mark Ernst

2.5 HR Accountability Report Assigned to: Mark Ernst

2.6 Plan of Accountability for Culture Assigned to: Melissa Rich

Chapter 3

3.1 Align Leadership Academy Assigned to: Jeff Hamm

3.2 Area Directors Involved with Academy Assigned to: Jeff Hamm

3.3 Strategic Guidelines for Area Directors Assigned to: Sarah Jarnagin

3.4 Strengthen Leadership Capacity Assigned to: Mark Ernst

3.5 Unify Academic Leadership Structure Assigned to: Cody Reutzel

3.6 Align AHLPs Implementation Strategy Assigned to: Cody Reutzel

Chapter 4

4.1 Track Contract‑Based Funding Assigned to: Lark Reynolds

Report No. 2025‑10 A Systemic Performance Audit of the Tooele County School District Key Changes for Improved Student Achievement, Governance, Policy Adherence, and Department Coordination Office of the Legislative Auditor General Report to the Utah Legislature 1975–2025

Audit Subcommittee

• President J. Stuart Adams, Co‑Chair — President of the Senate

• Speaker Mike Schultz, Co‑Chair — Speaker of the House

• Senator Kirk Cullimore — Senate Majority Leader

• Representative Casey Snider — House Majority Leader

• Senator Luz Escamilla — Senate Minority Leader

• Representative Angela Romero — House Minority Leader

Audit Staff

• Kade R. Minchey, Auditor General, CIA, CFE

• Darin R. Underwood, Manager, CIA

• Abigail Armstrong, Audit Supervisor

• Abigail Jacobsen, Audit Staff

• Kitty Mui, Audit Intern

• Zackery King, Consultant, CPA

Office of the Legislative Auditor General W315 House Building State Capitol Complex Salt Lake City, UT 84114 Phone: 801‑538‑1033

Transmittal Letter

June 18, 2025 To: The Utah State Legislature

Transmitted herewith is our report: “A Systemic Performance Audit of the Tooele County School District” [Report #2025‑10].

An audit summary is found at the front of the report. The scope and objectives of the audit are included in the audit summary. Each chapter has a corresponding chapter summary at its beginning.

Utah Code 36‑12‑15.3(2) requires the Office of the Legislative Auditor General to designate an audited entity’s chief officer. The designated chief officer for Tooele County School District is Superintendent Mark Ernst. Dr. Ernst has been notified that they must comply with the audit response and reporting requirements outlined in statute.

We will be happy to meet with appropriate legislative committees, individual legislators, and other state officials to discuss any item contained in the report to facilitate implementation of the recommendations.

Sincerely, Kade R. Minchey, CIA, CFE Auditor General kminchey@le.utah.gov

Table of Contents

Chapter 1 — Tooele County School District Needs to Significantly Improve Student Achievement 1.1 Tooele County School District Is Performing Below Most State Targets and Peer Districts 1.2 Inconsistencies Within Instructional Delivery May Contribute to Poor Student Achievement

Chapter 2 — Tooele County School District Needs to Enhance Governance to Better Target Accountability and Student Achievement 2.1 The Tooele County School District Board Can Significantly Improve Prioritizing Student Achievement 2.2 Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

Chapter 3 — Tooele County School District Needs to Better Address Poor Student Performance Through Quality Principalship and Key Department Coordination 3.1 Tooele County School District’s Principal Development and Coaching System Needs Improvement 3.2 Tooele County School District’s Key Departments Can Better Coordinate to Its Strategic Model

Chapter 4 — Tooele County School District and Other Local Education Agencies Need to Separately Account for Education Service Provider Funds 4.1 Insufficient Separation of Accounts and Inaccurate Communication Led to Tooele County School District’s Budget Deficits

Complete List of Audit Recommendations Appendices A. TCSD Student Achievement in Depth B. TCSD’s Strategic Model and Plan C. Teaching and Learning Annual High Leverage Practices D. Forensic Accounting Consultant Report Agency Response Plan

Tooele County School District — By the Numbers

Overview

Tooele County School District (TCSD) is a geographically large district in western northern Utah. Its strategic model focuses on ensuring that all focus areas, activities, and initiatives are purpose‑driven and aligned with district goals for student success.

District Statistics (FY 2024)

• 15,588 students

• 27 schools: 17 elementary, 3 middle, 5 high, 2 other

• 917 teachers; 2,274 total employees; 16% turnover rate

• 91.8% average attendance

• 25% economically disadvantaged students

• 6,941 square miles

Peer District Comparison (2024)

Average K–3 Proficiency

• TCSD: 57%

• Iron: 66%

• Cache: 72%

• Box Elder: 75%

Average Grades 3–10 Proficiency

• TCSD: 34%

• Iron: 49%

• Cache: 55%

• Box Elder: 41%

ACT Composite 18+

• TCSD: 56%

• Iron: 67%

• Cache: 71%

• Box Elder: 58%

Graduation Rate

• TCSD: 79%

• Iron: 91%

• Cache: 95%

• Box Elder: 87%

Instruction Spending Per Pupil

• TCSD: $7,498

• Iron: $6,220

• Cache: $7,293

• Box Elder: $7,722

Legislative Performance Metrics Met

• 2 of 7

Systemic Performance Audit — Tooele County School District

Audit Request

The Legislative Audit Subcommittee requested and prioritized a systemic performance audit of Tooele County School District (TCSD). This is the seventh audit of local education agencies (LEAs). This type of audit begins with a large scope that is narrowed as risks are identified.

Background

TCSD is located in the western part of northern Utah. The district has 27 schools across approximately 6,941 square miles, serving 15,588 students. Student achievement has typically been below state goals and peer districts.

TCSD has made many efforts to address this significant achievement gap, but more strategic change and accountability at every level of the district is needed to improve outcomes.

Key Findings

1.2 Inconsistencies within instructional delivery may have contributed to poor student achievement. 2.1 The Tooele County School District Board can significantly improve prioritizing student achievement. 2.2 Low morale and inadequate accountability created policy inefficiencies and noncompliance. 3.1 Tooele County School District’s principal development and coaching system needs improvement. 3.2 Tooele County School District’s key departments can better coordinate to its strategic model. 4.1 Tooele County School District and other local education agencies need to separately account for Education Service Provider funds.

Recommendations

1.1 TCSD should establish an assistant superintendent devoted to academics who will centralize the approach to improving student outcomes.

2.2 The TCSD Board should maintain a standing agenda item at all school board meetings addressing progress on student achievement.

2.4 The human resources department should implement systems ensuring consistency across the district with HR policies and procedures.

3.3 TCSD should assess the area director role to create guiding documents for instructional leadership.

3.5 TCSD should coordinate the work of the Departments of Teaching and Learning, Special Education, and Student Services.

4.1 TCSD should separately account for funds received from specific contracts based on student enrollment.

Report Summary

Tooele County School District Board Needs to Significantly Improve Prioritizing Student Achievement

Best practice shows that a lack of board governance contributes to inefficient policies and procedures, which hinders district‑wide goals, increases risk, and results in poor processes. The TCSD board lacks focus on student achievement and district goals, due to both being insufficiently outlined in policy.

Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

The audit found that TCSD generally lacks coordination between the board and leadership throughout the organization. TCSD also lacks consistency and compliance in some policy areas. This noncompliance, combined with low employee morale (as evidenced in the TCSD culture survey), has created an ineffective culture.

Tooele County School District’s Quality Principalships and Key Departments Coordination Needs Improvement

TCSD’s leadership training and coaching system for principals should better reflect school governance best practices, allowing principals to significantly impact student outcomes.

Effective districts strategically coordinate department initiatives to improve student outcomes. TCSD has not prioritized coordination of training, implementation, and calibration of initiatives among academic departments.

Separate Accounting Measures and Inaccurate Communication Regarding OpenEd Led to Budget Deficits

Financial mismanagement by a school district can harm student outcomes. TCSD should ensure that the district separately accounts for funds received from contracts and that those revenues are not used for ongoing funds.

Student Achievement Summary

Regardless of assessment type, subject, or grade, TCSD’s students are performing lower than most state targets and peer districts.

Acadience Proficiency (K–3)

• Literacy: 67% (Met target of 60%)

• Numeracy: 61%

RISE Proficiency (Grades 3–8)

• ELA: 39% (Target 63.33%)

• Math: 31% (Target 62.8%)

• Science: 34% (Target 65.67%)

ACT

• 18 or above: 56% (Target 73%)

Graduation Rate

• 79% (Target 92.1%)

Chapter 1 Summary

Tooele County School District Needs to Significantly Improve Student Achievement

Background

TCSD has 27 schools and over 15,000 students. The district has performed below state targets and peer districts in most standardized tests and graduation rates.

Finding 1.1

Tooele County School District Is Performing Below Most State Targets and Peer Districts No recommendation.

Finding 1.2

Inconsistencies Within Instructional Delivery May Contribute to Poor Student Achievement

Recommendation 1.1 TCSD should establish an assistant superintendent devoted to academics with direct authority to centralize the approach to improving student outcomes.

Recommendation 1.2 The TCSD Board should consider adjusting policy to allow for an additional assistant superintendent.

Recommendation 1.3 The assistant superintendent devoted to academics should establish excellence plans for each grade and subject area, including curriculum standards and performance goals.

Recommendation 1.4 The TCSD Board should develop a plan for tracking and monitoring performance goals established by the district.

Conclusion

Overall inconsistency within districtwide standardization has contributed to poor student achievement. Improvements in board governance, policy implementation, and organizational alignment could strengthen the district’s focus on high‑quality tier 1 instruction and improve student outcomes.

Tooele County School District Needs to Significantly Improve Student Achievement

Tooele County School District (TCSD), located in the western part of northern Utah, has 27 schools and over 15,000 students. This chapter provides an overview of TCSD’s assessment performance compared to state performance targets as well as peer school districts and focuses on TCSD’s poor proficiency. Overall inconsistency within districtwide standardization has contributed to poor student achievement for TCSD. The remainder of the report shows that adjustments in strategic board governance, implementation of district policies and initiatives, and overall organizational alignment could also help TCSD develop a greater focus on district‑wide goals of high‑quality tier 1 instruction, resulting in improved student outcomes.

1.1 Tooele County School District Is Performing Below Most State Targets and Peer Districts

House Bill (HB) 1 Public Education Base Budget Amendments (2024) established state assessment performance targets for all major student assessments. The state target for the Acadience assessment, an assessment for grades K–3, is set at 60 percent of students who should be “typical or better.” The following Figure 1.1 shows TCSD’s performance for Acadience in 2024 (see Figure 1 in Appendix A for performance over time). Notably, TCSD performed below its peer districts in literacy and most of its peer districts in numeracy.

Footnote 1: Response to Intervention (RTI) is a multi‑tiered system of support designed to provide comprehensive support to students. In this framework there are three tiers of education. Tier 1 instruction is research‑based core instruction that students receive in the general education classroom. As students need additional support, they move to tier 2 or 3.

Figure 1.1 (Text Description)

TCSD performed below most peer districts for Acadience Assessment (Grades 1–3) for School Year 2024. While below peer districts, TCSD did perform above the legislatively mandated target of 60% of students who should be at “typical or better” for Acadience testing in literacy by 1 percentage point and numeracy by 7 percentage points.

Source: USBE Acadience data.

HB 1 also set percentage targets of “proficient” or higher for the Readiness Improvement Success Empowerment (RISE) assessment, an assessment for grades 3–8 in English Language Arts (ELA) and Math, and grades 4–8 in Science. TCSD performed significantly below state targets and peer districts in the 2024 school year. This data is shown in Figure 1.2.

Figure 1.2 (Text Description)

TCSD RISE Assessment (Grades 3–8*) for School Year 2024 is consistently inadequate compared to its peer districts. TCSD is about 29 percentage points behind statewide targets for ELA, about 31 percentage points behind targets for math, and 26 percentage points behind statewide targets for science.

• ELA (Target 63.33%)

  • Box Elder: 41%

  • Cache: 57%

  • Iron: 49%

  • Tooele: 39%

• Math (Target 62.80%)

  • Box Elder: 45%

  • Cache: 63%

  • Iron: 47%

  • Tooele: 34%

• Science (Target 65.67%)

  • Box Elder: 48%

  • Cache: 64%

  • Iron: 55%

  • Tooele: 42%

Source: USBE RISE data. *Grades 4–8 for science.

The state target for the American College Testing (ACT), an assessment for grade 11, is set at 74 percent of students testing above a score of 18. TCSD needs to improve, as students are 18 percentage points below the state target. TCSD also performed below the state average of 61 percent for ACT. This data is shown in Figure 1.3.

Figure 1.3 (Text Description)

TCSD ACT (Grade 11) Assessment for School Year 2024 falls below its peer districts. Scores are 18 percentage points below the statewide target.

• Target: 74%

• Box Elder: 58%

• Cache: 71%

• Iron: 67%

• Tooele: 56%

Source: USBE ACT data.

The state target for graduation is 92.1 percent. TCSD needs to improve graduation rates, as they are 13 percentage points below the state target. TCSD’s graduation rate is also below the state average by 10 percentage points. This data is shown in Figure 1.4.

Figure 1.4 (Text Description)

TCSD Graduation Rates for 2024. TCSD students graduated well below peer districts and 13 points below the state target.

• Target: 92.1%

• Box Elder: 87%

• Cache: 96%

• Iron: 91%

• Tooele: 79%

Source: USBE graduation data.

TCSD is performing generally lower than state averages, state targets, and peer districts.

Regardless of assessment type, subject, or grade, TCSD’s students are generally performing lower than the state targets and peer districts, and have done so since 2019, where we began our analysis (see Appendix A). TCSD needs to prioritize student achievement and take strategic steps to improve the district’s quality of education. The rest of this chapter highlights actions that both TCSD and the audit team determined could have positive impacts on student achievement.

1.2 Inconsistencies Within Instructional Delivery May Contribute to Poor Student Achievement

As previously discussed, TCSD’s student achievement is typically below state targets and peer districts. TCSD and the audit team identified that the quality of tier 1 instruction needs significant improvement. TCSD has not previously held teachers accountable to a high standard of instruction, but TCSD is currently implementing initiatives that should positively impact student achievement. The district needs to address the lack of comprehensive analysis of student data, inconsistent use of primary instructional materials, and absence of goals and plans for all grade levels.

The TCSD school board has not prioritized student achievement. The board has rarely engaged in discussions about district strategic goals and student achievement. Because of this, TCSD has not prioritized centralizing analysis and goal setting for academic achievement. TCSD should create an assistant superintendent devoted to academics, where that individual would take ownership of student performance goals and data.

Instructional Leadership, Strategic Focus, and Observed Inconsistencies

TCSD Needs a Position Responsible for Creating a Centralized Focus on Academics

Ineffective approaches to instruction and inconsistent use of primary instructional materials by teachers have contributed to TCSD’s poor performance. District leaders are aware of poor academic performance and are actively implementing new initiatives to support teachers in delivering a higher standard of instruction. But TCSD lacks a leadership position that streamlines academic performance and metrics in order to hold administrators and teachers accountable to this higher standard of education.

The TCSD school board has not been focused on student achievement and has not recognized the importance of having a member of leadership devoted to aligning academic analysis and goals. Therefore, TCSD should create an assistant superintendent devoted to academics with the authority to oversee and implement academic initiatives and report directly to the superintendent and TCSD school board.

The district is in the process of implementing a Strategic Model (see Appendix B) that seeks to improve student outcomes through the development of Annual High Leverage Practices (AHLPs). These AHLPs are yearly initiatives intended to systematically establish practices that are fundamental to a high‑functioning education system. TCSD is in the early implementation stages of this model, so the potential impacts to student achievement have not been seen.

TCSD Needs Better Strategic Focus and More Urgency for Academic Achievement

Instruction needs significant improvement because of a lack of long‑term strategic focus on academics. During visits to 15 low‑performing TCSD schools, the audit team observed widely varied approaches to instructional delivery. There were multiple curriculums for tier 2 instruction, inconsistent structures and schedules for interventions, and varied professional learning community (PLC) structure and accountability. The lack of academic strategy has contributed to poor student achievement, with TCSD students typically performing below state averages, targets, and peer districts.

The 15 low‑performing schools we observed had varied approaches to instruction.

There has been a lack of strategic focus and urgency regarding academic achievement in TCSD. TCSD has not held its teachers accountable for high‑quality education. In TCSD, there is no specific employee dedicated to developing standards and comprehensively analyzing student performance. There are multiple departments assessing various aspects of student performance and setting goals, but these efforts are not centralized.

Ensuring that there is a centralized approach to assessing student performance would strategically improve student outcomes in the district. Therefore, TCSD should create an assistant superintendent devoted to academics who would be responsible for centralizing the approach to improving student outcomes within TCSD.

TCSD policy states that the district shall have one assistant superintendent. The TCSD School Board should consider ways to improve student achievement, including adjusting policy to allow for more than one assistant superintendent.

RECOMMENDATION 1.2

The Tooele County School District Board should consider ways to improve student achievement, including adjusting policy to allow for an additional assistant superintendent.

RECOMMENDATION 1.1

Tooele County School District should prioritize student achievement by establishing an assistant superintendent devoted to academics, who will have the direct authority to centralize the approach to improving student outcomes in the district.

Instruction Is Inconsistent Among TCSD Schools

The audit team observed inconsistent implementation of instruction in TCSD schools. For example, in an observation at one school, the audit team found two classes that were supposed to be teaching similar material but were discussing vastly different topics. TCSD leaders are aware of this and recognized that teachers have not been held accountable to a high standard of instruction.

There are existing concerns about teachers not using board‑approved primary instructional material for classroom instruction. The following figure describes teacher use of primary instructional materials.

Observed Use of Primary Instructional Materials (Text Description)

• Only 26% of teachers and students accessed the enVisionMATH software in a 100‑day sample.

• Teaching and Learning staff observed that 32% of the time, primary instructional materials were not used in the 2024–2025 school year.

• Only 38% of teachers and students accessed the McGraw Hill software in a 30‑day sample.

Source: Teaching and Learning staff, survey, and software.

Note: Primary instructional materials are the district‑selected, board‑approved core resources a teacher uses to deliver lessons and support student learning. Online software data is not completely reliable but is the best data available to track teachers using primary instructional materials.

These percentages are troubling because they demonstrate the lack of use of board‑approved, district‑provided primary instructional material. A case study of a school district in Texas recognized the importance of consistent classroom instruction. In its new education system, each high‑quality lesson delivered by teachers is pre‑written using its curriculum map and learning objectives, creating consistency in using classroom primary instructional materials.

TCSD should create a system of accountability to ensure that teachers are using primary instructional materials through rigorous goals and curriculum planning. TCSD has already seen some success in its student growth by establishing effective curriculum and goals in its kindergarten excellence plan.

TCSD Teachers and Students Need to Be Held Accountable Through Excellence Plans

TCSD implemented a kindergarten excellence plan to implement the science of reading practices in classrooms and improve student learning in kindergarten literacy. The plan was implemented during the 2023–2024 school year. The kindergarten excellence plan uses Letter‑A‑Day as well as blending and segmenting routines to meet the following goals:

1. Students will know all uppercase and lowercase letters and all letter sounds by December 1st.

2. Students will be able to read eight whole words on the end‑of‑year nonsense word fluency assessment.

These objectives should help TCSD achieve the following goal in its early learning plan:

Increase the percentage of kindergarten students at or above benchmark on the Acadience Reading composite from beginning of year to end of year by 21 percentage points.

This plan details the expectations of key stakeholders: the ELA curriculum director, area directors, principals, literacy coaches, and teachers. Each stakeholder has specific roles they play in accomplishing these goals.

TCSD has seen great success in growth from the beginning of the 2024–2025 school year to the middle of the year.

• Beginning of year kindergarten proficiency: 50%

• Middle of year kindergarten proficiency: 74%

This demonstrates that when TCSD teachers are held accountable for their teaching with clear curriculum and goals, student achievement can improve.

Excellence Plans, RISE Trends, and Recommendations

In contrast to kindergarten, other grades where excellence plans with performance metrics have not been established have not shown significant growth. From the beginning of the 2024–2025 school year to the middle of the year in Acadience literacy proficiency:

• Grade 1 grew six percent

• Grade 2 had no growth

• Grade 3 decreased by one percent

Additionally, on RISE in grades 3–8, the scores have not increased. This is shown in Figure 1.5.

Figure 1.5 (Text Description)

TCSD Grades Without an Excellence Plan (Grades 3–8) Have Not Improved Over Time. This reinforces that district instruction needs to change.

Trend lines from 2019 to 2024 show little to no improvement across grades 3–8 in RISE proficiency.

Source: USBE RISE data.

The success in mid‑year growth from the kindergarten excellence plan shows that holding teachers to a high standard of education positively impacts student growth. TCSD needs to hold all teachers to a high standard of education through excellence plans, which include establishing clear standards for curriculum and goals.

The assistant superintendent devoted to academics should establish curriculum standards and performance goals through excellence plans for each grade and subject content area. The TCSD school board can also play an active role in excellence plans by developing a plan for tracking and reviewing the performance goals established through excellence plans.

RECOMMENDATION 1.3

Tooele County School District’s assistant superintendent devoted to academics, as recommended in Recommendation 1.1 of this report, should establish excellence plans for each grade and subject content area that establish curriculum standards and performance goals to improve student outcomes across the district and effectively monitor those goals.

RECOMMENDATION 1.4

The Tooele County School District Board should establish a plan for tracking and monitoring the performance goals established by the district.

CHAPTER 2 SUMMARY

Tooele County School District Needs to Enhance Governance to Better Target Accountability and Student Achievement

Background

Tooele County School District (TCSD) would benefit from better board alignment with district goals. The board should ensure its work prioritizes student achievement and strategic planning. TCSD needs more efficient policy review and implementation processes to decrease the risk of policy noncompliance.

Finding 2.1

The Tooele County School District Board Can Significantly Improve Prioritizing Student Achievement

(The full text of this finding will appear in the next section.)

Finding 2.2

Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

(Full text continues in the next section.)

Chapter 2

Tooele County School District Needs to Enhance Governance to Better Target Accountability and Student Achievement

Background

Tooele County School District (TCSD) would benefit from better board alignment with district goals. The board should ensure its work prioritizes student achievement and strategic planning. TCSD needs more efficient policy review and implementation processes to decrease the risk of policy noncompliance.

Finding 2.1

The Tooele County School District Board Can Significantly Improve Prioritizing Student Achievement

Best practice shows that a lack of board governance contributes to inefficient policies and procedures, which hinders district‑wide goals, increases risk, and results in poor processes. The TCSD board lacks focus on student achievement and district goals, due to both being insufficiently outlined in policy.

The board has not prioritized student achievement in its meetings, discussions, or policy structure. Board agendas rarely include items related to student performance, academic progress, or districtwide instructional goals. Without consistent attention to student achievement, the board cannot effectively guide or monitor district progress.

The board’s policies do not clearly define expectations for academic oversight, nor do they establish a framework for monitoring student outcomes. This lack of clarity contributes to inconsistent implementation of district initiatives and weak accountability structures.

The board should revise its policies to ensure that student achievement is a central focus of its governance responsibilities. This includes establishing clear expectations for academic monitoring, setting measurable goals, and regularly reviewing progress toward those goals.

Finding 2.2

Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

The audit found that TCSD generally lacks coordination between the board and leadership throughout the organization. TCSD also lacks consistency and compliance in some policy areas. In our view, this noncompliance has combined with low employee morale, evidenced in our TCSD culture survey, to create an ineffective culture.

Employees reported feeling unsupported, unclear about expectations, and disconnected from district leadership. Many expressed concerns about inconsistent enforcement of policies, unclear communication, and a lack of follow‑through on district initiatives.

The audit team identified several areas where policies were not consistently implemented or monitored. These included:

• Inconsistent application of human resources policies

• Lack of standardized procedures across schools

• Limited oversight of instructional expectations

• Insufficient follow‑up on district initiatives

These issues contribute to confusion, frustration, and reduced trust in leadership. Without strong accountability systems, district initiatives are implemented unevenly, reducing their effectiveness and undermining district goals.

Improving morale and accountability will require clearer policies, consistent enforcement, and stronger communication between leadership and staff.

SECTION 8 — CHAPTER 2 (Full Text, Part 2)

Governance Weaknesses, Policy Inefficiencies, and Accountability Gaps

Continuation of Finding 2.2

Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

The audit team found that TCSD lacks coordination between the board and district leadership. This lack of coordination has contributed to inconsistent implementation of policies and initiatives. Many employees reported that expectations were unclear and that district leadership did not consistently communicate or enforce policies.

The TCSD culture survey revealed low morale among employees. Staff expressed concerns about:

• Lack of support from district leadership

• Inconsistent enforcement of policies

• Limited communication about district initiatives

• Unclear expectations for performance

• Insufficient follow‑through on district goals

These issues have created an ineffective culture that undermines district operations and student achievement. When employees do not feel supported or informed, they are less likely to implement district initiatives consistently or effectively.

The audit team also identified several areas where policy noncompliance was common. These included:

• Inconsistent application of human resources procedures

• Lack of standardized processes across schools

• Limited oversight of instructional expectations

• Insufficient monitoring of district initiatives

These issues increase risk for the district and hinder progress toward districtwide goals.

Governance and Policy Structure Need Improvement

The TCSD board’s policies do not clearly outline expectations for academic oversight or define how the board should monitor student achievement. Without clear policies, the board cannot effectively guide district leadership or hold them accountable for results.

The board also lacks a structured process for reviewing and updating policies. Many policies are outdated, unclear, or inconsistently applied. This contributes to confusion among staff and reduces the effectiveness of district operations.

The audit team found that:

• Board agendas rarely include student achievement updates

• Strategic planning is not consistently discussed or monitored

• Policies do not clearly define roles and responsibilities

• There is no systematic process for evaluating district progress

Improving governance will require the board to revise its policies, prioritize student achievement, and establish clear expectations for district leadership.

Board Oversight of Student Achievement Is Insufficient

The board does not regularly review data related to student performance. Without consistent monitoring, the board cannot identify trends, evaluate the effectiveness of district initiatives, or make informed decisions about resource allocation.

The board should:

• Establish a standing agenda item for student achievement

• Review progress toward district goals at every meeting

• Require regular reports from district leadership

• Ensure that policies reflect a commitment to academic improvement

These steps would strengthen accountability and help the district focus on improving student outcomes.

Human Resources Issues, Policy Inconsistencies, and Governance Recommendations

Human Resources Policies Are Inconsistently Applied Across the District

The audit team found that TCSD’s human resources (HR) policies and procedures are not consistently implemented across the district. Several schools and departments reported different interpretations of HR policies, leading to inconsistent practices in areas such as:

• Employee onboarding

• Performance evaluations

• Leave and attendance procedures

• Disciplinary actions

• Documentation requirements

These inconsistencies create confusion for employees and increase the risk of noncompliance with district policy and state requirements.

Some employees reported that HR processes varied depending on the school or supervisor. Others noted that they were unsure where to find current policies or how to follow them correctly. This lack of clarity contributes to frustration and reduces trust in district leadership.

The audit team also found that HR did not have adequate systems in place to ensure that policies were applied uniformly. Without centralized oversight and consistent procedures, the district cannot ensure fairness, compliance, or accountability.

Policy Implementation Is Inefficient and Lacks Monitoring

TCSD lacks a structured process for reviewing, updating, and implementing policies. Many policies are outdated, unclear, or not aligned with current district practices. Additionally, the district does not have a system to ensure that staff are trained on updated policies or that policies are consistently followed.

The audit team observed:

• Limited communication about policy changes

• No standardized training for staff on new or revised policies

• Inconsistent documentation of policy implementation

• Lack of monitoring to ensure compliance

These issues contribute to inefficiencies and increase the risk of errors or noncompliance.

Board Governance Needs Stronger Alignment With District Goals

The board’s governance structure does not adequately support the district’s strategic goals. The board does not consistently review progress toward district goals, nor does it have a clear process for evaluating the effectiveness of district initiatives.

The audit team found that:

• Board meetings rarely include updates on student achievement

• Strategic planning is not consistently monitored

• Board policies do not clearly define roles and responsibilities

• There is no formal process for evaluating district leadership on academic outcomes

Improving governance will require the board to revise its policies, prioritize student achievement, and establish clear expectations for district leadership.

RECOMMENDATION 2.2

The Tooele County School District Board should maintain a standing agenda item on all school board meetings that addresses the district’s progress on student achievement.

RECOMMENDATION 2.4

The human resources department should implement systems for ensuring consistency across the district with human resources policies and procedures.

Principal Development, Coaching Systems, and Leadership Expectations

Chapter 3

Tooele County School District Needs to Better Address Poor Student Performance Through Quality Principalship and Key Department Coordination

3.1 Tooele County School District’s Principal Development and Coaching System Needs Improvement

Principals play a critical role in improving student outcomes. Effective principals create strong school cultures, support high‑quality instruction, and ensure that teachers are held accountable for student learning. However, TCSD’s current system for developing and supporting principals does not adequately prepare them to fulfill these responsibilities.

The audit team found that TCSD’s leadership training and coaching system for principals lacks structure, consistency, and alignment with best practices. Principals reported that they did not receive clear expectations, consistent feedback, or targeted coaching to help them improve instructional leadership.

Several issues were identified:

• Lack of clear instructional leadership expectations. Principals were not provided with a consistent framework outlining what high‑quality instructional leadership looks like in TCSD.

• Inconsistent coaching and support. Some principals received regular coaching, while others received little to none.

• Limited monitoring of principal performance. The district did not have a structured process for evaluating principals on instructional leadership or student outcomes.

• Insufficient training for new principals. New principals reported feeling unprepared for the instructional leadership responsibilities of their role.

Without a strong system for developing and supporting principals, TCSD cannot ensure that school leaders are equipped to drive improvements in teaching and learning.

Principals Need Clear Expectations and Consistent Coaching

Effective school districts provide principals with:

• Clear instructional leadership standards

• Regular coaching aligned to those standards

• Feedback based on classroom observations and student data

• Professional development tailored to leadership needs

TCSD’s current system does not include these components in a consistent or structured way. As a result, principals may not know what is expected of them or how to improve their practice.

The audit team found that area directors, who are responsible for supervising principals, did not have clear guidance on how to support instructional leadership. This contributed to inconsistent coaching and limited accountability.

Leadership Training Is Not Aligned With Best Practices

TCSD provides some leadership training, but it is not aligned with a comprehensive framework for instructional leadership. Training sessions are not part of a coherent system and do not consistently address the skills principals need to improve student outcomes.

Principals reported that:

• Training topics varied widely

• Sessions were not connected to district goals

• There was limited follow‑up or application support

• Training did not address the most critical aspects of instructional leadership

This lack of alignment reduces the effectiveness of leadership development efforts.

Principal Evaluations Do Not Emphasize Instructional Leadership

The audit team found that principal evaluations did not consistently include measures related to instructional leadership or student achievement. Without clear expectations and accountability, principals may not prioritize the instructional aspects of their role.

Effective evaluation systems include:

• Clear performance standards

• Evidence‑based measures

• Regular feedback

• Alignment with district goals

TCSD’s current system does not meet these criteria.

Area Director Role, Department Coordination, and Recommendations

Area Directors Need Clear Guidance for Supporting Principals

Area directors are responsible for supervising principals and supporting their development. However, the audit team found that area directors did not have clear expectations or guiding documents outlining how they should support instructional leadership.

Without clear guidance, area directors provided inconsistent coaching and oversight. Some principals received regular feedback and support, while others received minimal interaction. This inconsistency contributed to uneven implementation of district initiatives and limited accountability for instructional quality.

The district does not have a standardized framework that defines:

• The responsibilities of area directors

• Expectations for principal coaching

• How instructional leadership should be monitored

• How feedback should be documented and followed up

This lack of structure reduces the effectiveness of the district’s leadership pipeline and weakens instructional oversight.

TCSD Should Create Guiding Documents for Instructional Leadership

To improve consistency and accountability, TCSD should develop guiding documents that clearly outline expectations for instructional leadership. These documents should define:

• What effective instructional leadership looks like

• How principals will be coached and evaluated

• The role of area directors in supporting principals

• How instructional practices will be monitored across schools

Clear expectations would help ensure that principals receive consistent support and that instructional leadership is aligned with district goals.

RECOMMENDATION 3.3

Tooele County School District should assess the area director role to create guiding documents for instructional leadership.

3.2 Tooele County School District’s Key Departments Can Better Coordinate to Its Strategic Model

Effective school districts strategically coordinate department initiatives to improve student outcomes. TCSD has not prioritized coordination among its academic departments, including:

• Teaching and Learning

• Special Education

• Student Services

The audit team found that these departments often worked independently rather than collaboratively. This lack of coordination led to:

• Duplicated efforts

• Conflicting initiatives

• Inconsistent expectations for schools

• Limited alignment with the district’s Strategic Model

When departments do not work together, schools receive mixed messages about priorities and expectations. This contributes to confusion and reduces the effectiveness of district initiatives.

Departments Need to Align Their Work With the Strategic Model

TCSD’s Strategic Model is intended to guide districtwide improvement efforts. However, the audit team found that key departments were not consistently aligning their work with the model.

Examples of misalignment included:

• Different departments providing separate trainings on similar topics

• Inconsistent messaging about instructional expectations

• Lack of shared goals or coordinated planning

• Limited collaboration on professional development

To improve student outcomes, TCSD must ensure that all academic departments work together and align their efforts with the Strategic Model.

RECOMMENDATION 3.5

Tooele County School District should coordinate the work of the Departments of Teaching and Learning, Special Education, and Student Services.

Financial Management, ESP Funds, and Budget Deficits

Chapter 4

Tooele County School District and Other Local Education Agencies Need to Separately Account for Education Service Provider Funds

4.1 Insufficient Separation of Accounts and Inaccurate Communication Led to Tooele County School District’s Budget Deficits

Financial mismanagement by a school district can harm student outcomes. TCSD should ensure that the district separately accounts for funds received from contracts and that those revenues are not used for ongoing funds.

The audit team found that TCSD did not properly separate Education Service Provider (ESP) funds from other district funds. ESP funds are generated through contracts based on student enrollment and are intended for specific purposes. When these funds are not tracked separately, the district risks overspending or misallocating resources.

TCSD’s failure to separate ESP funds contributed to budget deficits. The district used ESP revenues to cover ongoing expenses without ensuring that the funds were sufficient to support those costs. This practice created structural imbalances in the budget.

Additionally, inaccurate communication between departments contributed to misunderstandings about available funds. Some departments believed they had more funding available than they actually did, leading to overspending.

The audit team identified several issues:

• ESP funds were not tracked in separate accounts

• Revenues were used for ongoing expenses without long‑term planning

• Departments were not consistently informed about actual fund balances

• Budget projections did not accurately reflect available ESP revenues

• Financial reports lacked clarity and transparency

These issues increased the risk of financial instability and contributed to the district’s budget deficits.

Need for Separate Accounting of ESP Funds

ESP contracts generate revenue based on student enrollment. These funds must be accounted for separately to ensure compliance with contract requirements and to maintain financial transparency.

When ESP funds are combined with general district funds:

• It becomes difficult to determine whether funds are being used appropriately

• The district may unintentionally violate contract terms

• Financial reporting becomes less accurate

• Budget planning becomes more challenging

The audit team recommends that TCSD establish separate accounts for ESP funds and implement procedures to ensure accurate tracking and reporting.

RECOMMENDATION 4.1

Tooele County School District should separately account for funds received from specific contracts based on student enrollment.

SECTION 13 — COMPLETE LIST OF AUDIT RECOMMENDATIONS

All Recommendations from Chapters 1–4

Chapter 1 Recommendations

Improving Student Achievement and Instructional Consistency

Recommendation 1.1 Tooele County School District should prioritize student achievement by establishing an assistant superintendent devoted to academics, who will have the direct authority to centralize the approach to improving student outcomes in the district.

Recommendation 1.2 The Tooele County School District Board should consider ways to improve student achievement, including adjusting policy to allow for an additional assistant superintendent.

Recommendation 1.3 The assistant superintendent devoted to academics should establish excellence plans for each grade and subject content area that establish curriculum standards and performance goals to improve student outcomes across the district and effectively monitor those goals.

Recommendation 1.4 The Tooele County School District Board should establish a plan for tracking and monitoring the performance goals established by the district.

Chapter 2 Recommendations

Enhancing Governance, Accountability, and Policy Alignment

Recommendation 2.2 The Tooele County School District Board should maintain a standing agenda item on all school board meetings that addresses the district’s progress on student achievement.

Recommendation 2.4 The human resources department should implement systems for ensuring consistency across the district with human resources policies and procedures.

Chapter 3 Recommendations

Improving Principalship and Department Coordination

Recommendation 3.3 Tooele County School District should assess the area director role to create guiding documents for instructional leadership.

Recommendation 3.5 Tooele County School District should coordinate the work of the Departments of Teaching and Learning, Special Education, and Student Services.

Chapter 4 Recommendations

Improving Financial Management and ESP Fund Tracking

Recommendation 4.1 Tooele County School District should separately account for funds received from specific contracts based on student enrollment.

SECTION 14 — APPENDICES (Part 1)

Appendix A: TCSD Student Achievement in Depth (Based on all text available in the uploaded document)

Appendix A — TCSD Student Achievement in Depth

Title: TCSD Student Achievement in Depth

Referenced in earlier chapters:

• Appendix A includes Figure 1 (Acadience performance over time).

• Appendix A is cited as the source for longitudinal data beginning in 2019.

SECTION 15 — APPENDICES (Part 2)

Appendix B: TCSD’s Strategic Model and Plan

Appendix B — TCSD’s Strategic Model and Plan

Title: TCSD’s Strategic Model and Plan

Referenced in earlier chapters:

• The Strategic Model includes Annual High Leverage Practices (AHLPs).

• The model is in early implementation stages.

• It is intended to improve student outcomes through systematic practices.

SECTION 16 — APPENDICES (Part 3)

Appendix C: Teaching and Learning Annual High Leverage Practices

Appendix C — Teaching and Learning Annual High Leverage Practices

Title: Teaching and Learning Annual High Leverage Practices

Referenced in earlier chapters:

• AHLPs are yearly initiatives intended to establish foundational instructional practices.

• They are part of the Strategic Model.

• TCSD is in early implementation stages.

SECTION 17 — APPENDICES (Part 4)

Appendix D: Forensic Accounting Consultant Report

Appendix D — Forensic Accounting Consultant Report

Title: Forensic Accounting Consultant Report

Referenced in earlier chapters:

• Appendix D contains a detailed financial analysis related to ESP funds and budget deficits.

SECTION 18 — AGENCY RESPONSE PLAN

Agency Response Plan

SYSTEMIC PERFORMANCE AUDIT

AUDIT REQUEST

The Legislative Audit Subcommittee requested and prioritized a systemic performance audit of Tooele County School District (TCSD). This is the seventh audit of local education agencies (LEAs). This type of audit has an initially large scope that is reduced as risks are identified.

BACKGROUND

TCSD is located in the western part of northern Utah. TCSD has 27 schools across approximately 6,941 square miles, with 15,588 students. The district’s student achievement has typically been below state goals and peer districts. TCSD has made many efforts to address this significant achievement gap, but more strategic change and accountability at every level of the district is needed to improve the existing achievement gap.

TOOELE COUNTY SCHOOL DISTRICT

KEY FINDINGS

1.2 Inconsistencies Within Instructional Delivery May Have Contributed to Poor Student Achievement 2.1 The Tooele County School District Board Can Significantly Improve Prioritizing Student Achievement 2.2 Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance 3.1 Tooele County School District’s Principal Development and Coaching System Needs Improvement 3.2 Tooele County School District’s Key Departments Can Better Coordinate to Its Strategic Model 4.1 Tooele County School District and Other Local Education Agencies Need to Separately Account for Education Service Provider Funds

RECOMMENDATIONS

1.1 Tooele County School District should establish an assistant superintendent devoted to academics who will centralize the approach to improving student outcomes in the district.

2.2 The Tooele County School District Board should maintain a standing agenda item on all school board meetings that addresses the district’s progress on student achievement.

2.4 The human resources department should implement systems for ensuring consistency across the district with human resources policies and procedures.

3.3 Tooele County School District should assess the area director role to create guiding documents for instructional leadership.

3.5 Tooele County School District should coordinate the work of the Departments of Teaching and Learning, Special Education, and Student Services.

4.1 Tooele County School District should separately account for funds received from specific contracts based on student enrollment.

REPORT SUMMARY

Tooele County School District Board Needs to Significantly Improve Prioritizing Student Achievement

Best practice shows that a lack of board governance contributes to inefficient policies and procedures, which hinders district‑wide goals, increases risk, and results in poor processes. The TCSD board lacks focus on student achievement and district goals, due to both being insufficiently outlined in policy.

Low Morale and Inadequate Accountability Created Policy Inefficiencies and Noncompliance

We found that TCSD generally lacks coordination between the board and leadership down through the organization. TCSD also lacks consistency and compliance in some policy areas. In our view, this noncompliance has combined with low employee morale, evidenced in our TCSD culture survey, to create an ineffective culture.

Tooele County School District’s Quality Principalships and Key Departments Coordination Needs Improvement

TCSD’s leadership training and coaching system for principals should better reflect school governance best practices, allowing principals to significantly impact student outcomes.

Effective districts strategically coordinate department initiatives throughout the district to improve student outcomes. TCSD has not prioritized the coordination of training, implementing, and calibrating of initiatives among academic departments.

Separate Accounting Measures and Inaccurate Communication Regarding OpenEd Led to Budget Deficits

Financial mismanagement by a school district can harm student outcomes. TCSD should ensure that the district separately accounts for funds received from contracts and that those revenues are not used for ongoing funds.

Tooele County School District Needs to Significantly Improve Student Achievement

Regardless of assessment type, subject, or grade, TCSD’s students are performing lower than most state targets and peer districts.

Acadience Proficiency

Literacy: 67% (Met target of 60%) Numeracy: 61%

RISE Proficiency

ELA: 39% (Target 63.33%) Math: 31% (Target 62.8%) Science: 34% (Target 65.67%)

ACT

18 or Above on ACT: 56% (Target 73%)

Graduation Rate

Graduate: 79% (Target 92.1%)

Cover Letter

June 10, 2025

Kade R. Minchey, CIA, CFE, Auditor General Office of the Legislative Auditor General Utah State Capitol Complex Rebecca Lockhart House Building, Suite W315 PO Box 145315 Salt Lake City, UT 84114‑5315

Dear Mr. Minchey,

We appreciate the opportunity to respond to the recommendations from A Systemic Performance Audit of the Tooele County School District. The professionalism, trust, and collaborative spirit demonstrated by the audit team resulted in a positive experience. We welcomed the opportunity for an external review of the Tooele County School District and embraced this audit with full cooperation, transparency, and humility. We are committed to continuous learning and improvement to ensure the Tooele County School District students have the knowledge, skills, and dispositions they need to achieve their potential.

We agree with the recommendations presented by the audit team and commit to implementing them. The following pages contain our specific responses to each recommendation, the primary contact for implementation, as well as what our plan is, how we will take steps to accomplish the plan, the documentation we will produce to show progress, and when we desire to have full implementation of the recommendation. I am confident in the capacity of our organization and those assigned to these efforts to implement the audit recommendations successfully.

The Tooele County School District embraces continuous improvement for our employees and students. We value feedback and growth opportunities to improve our practice. This audit serves as a valuable assessment of our work, giving actionable insights into the efforts we should continue and areas in which we can learn and improve.

Dr. Mark Ernst, Superintendent Melissa Rich, Board President

Tooele County School District 92 Lodestone Way Tooele, Utah 84074‑8050 435.833.1900 FAX 435.833.1912 www.tooeleschools.org

Board of Education: Melissa Rich, President Robert Gowans, Vice President Members: Todd Thompson, Scott Bryan, ValaRee Shields, Emily Syphus, Elizabeth Smith Dr. Mark Ernst, Superintendent Lark Reynolds, Business Administrator

Chapter 1 Responses

Recommendation 1.1

The Tooele County School District should prioritize student achievement by establishing an assistant superintendent devoted to academics, who will have the direct authority to centralize the approach to improving student outcomes in the district.

District Response: The district concurs.

Contact: Dr. Mark Ernst, Superintendent mernst@tooeleschools.org (435) 833‑1900

What: TCSD will recommend the establishment of an assistant superintendent devoted to academics to the Board of Education. This assistant superintendent will be responsible for centralizing our academic approach and improving student academic performance.

How: The assistant superintendent devoted to academics will oversee the Academic Strategy Team (AST). Members of the AST include the Superintendency, Area Directors, Director of Special Education, Director of Student Services, Director of Assessment, and the Assistant Director of Teaching and Learning. The AST will work in concert to establish the academic approach for TCSD.

Documentation:

• Minutes from TCSD Board Meetings documenting discussion and decisions

• Agendas from AST meetings documenting the district’s academic approach

• Identified assessment data used to track effectiveness

When: The Board will discuss and decide on the position no later than September 9, 2025. The assistant superintendent and AST will establish the academic approach and identify assessment data no later than January 2026.

Recommendation 1.2

The Tooele County School District School Board should consider ways to improve student achievement, including adjusting policy to allow for an additional assistant superintendent.

District Response: The district concurs.

Contact: Melissa Rich, Board President mrich@tooeleschools.org (702) 622‑5186

What: TCSD will recommend a policy change to allow for an additional assistant superintendent.

How: TCSD will recommend modifying Policy 2002 to allow more than one assistant superintendent. The Board will request regular academic updates from the superintendency and consider additional strategies to improve student performance.

Documentation:

• Board meeting minutes showing discussion and decisions

• Minutes reflecting academic updates from TCSD staff

When: Recommendation will be presented no later than September 9, 2025. Full implementation by October 2025.

Recommendation 1.3

TCSD’s assistant superintendent devoted to academics should establish excellence plans for each grade and subject content area.

District Response: The district concurs.

Contact: Dr. Cody Reutzel, Executive Director of Teaching & Learning creutzel@tooeleschools.org (435) 833‑1900

What: Excellence plans will be established for each grade level.

How: The assistant superintendent will collaborate with district leaders, area directors, school leaders, and relevant personnel to establish strategies and performance goals.

Documentation: Each excellence plan will be published annually.

When: All plans will be completed and published by October 1 each year.

Recommendation 1.4

The Board should establish a plan for tracking and monitoring performance goals established by the district.

District Response: The district concurs.

Contact: Melissa Rich, Board President mrich@tooeleschools.org (702) 622‑5186

What: The Board will track performance goals throughout each school year.

How:

• Excellence plans presented in September

• Progress updates provided in February and June

• Board discussion and direction provided as needed

Documentation: Board agendas and minutes in September, February, and June will include excellence plan review.

When: Implementation begins in the 2025–2026 school year.

Chapter 2 Responses

Recommendation 2.1

The Tooele County School District Board should prioritize student achievement in its current policies on board power and duties, as well as mission statement and district goals.

District Response: The district concurs.

Contact: Melissa Rich, President, Tooele County School District Board of Education mrich@tooeleschools.org (702) 622‑5186

What: The Board of Education will more intentionally prioritize student achievement in policy and district goals.

How: TCSD will recommend modifying Policy 1001 to emphasize student achievement. District goals and key actions for improvement will also emphasize student achievement.

Documentation:

• Board meeting minutes reflecting recommended modifications to Policy 1001

• Minutes reflecting annual review of district mission and goals for alignment with academic outcomes

When: Changes to Policy 1001, if approved, will occur no later than the September 9, 2025 board meeting. The board will then establish a timeline for annual review of mission and goals. Implementation is ongoing based on the established schedule.

Recommendation 2.2

The Tooele County School District Board should maintain a standing agenda item on all school board meetings that addresses the district’s progress on student achievement.

District Response: The district concurs.

Contact: Melissa Rich, Board President mrich@tooeleschools.org (702) 622‑5186

What: The Board will create a standing agenda item for each meeting to address progress on student achievement.

How: The Board President will create the standing agenda item and work with the superintendency to establish criteria for executive staff briefings. This agenda item aligns with Recommendation 1.4.

Documentation: Board meeting agendas and minutes will reflect implementation.

When: The standing agenda item will be established during the August 12, 2025 board meeting.

Recommendation 2.3

TCSD should align its policies and goals to unify its governance message by creating a job description for the Director of Policy that includes clear authority for ensuring policies are unified and consistently updated and created.

District Response: The district concurs.

Contact: Dr. Mark Ernst, Superintendent mernst@tooeleschools.org (435) 833‑1900

What: TCSD will create a job description for the Director of Policy with clear authority for unifying and consistently updating district policy.

How: The Superintendent will work with the Directors of Policy and Human Resources to create the job description.

Documentation: The completed job description will serve as documentation.

When: The job description will be completed no later than September 24, 2025. The policy director will begin implementing duties immediately thereafter.

Recommendation 2.4

The human resources department should implement systems for ensuring consistency across the district with human resources policies and procedures, including proper documentation acquisition and maintenance.

District Response: The district concurs.

Contact: Dr. Mark Ernst, Superintendent mernst@tooeleschools.org (435) 833‑1900

What: TCSD will review HR policies and procedures and implement systems to ensure consistency, including proper documentation acquisition and maintenance.

How: The Superintendent will meet with the HR Director and team to determine the best course of action. The review will identify systems needing change and new measures to be instituted.

Documentation:

• Systems put in place

• Training modules

• Proper documentation acquisition

• Maintenance of HR materials

When: The Superintendent and HR team will meet no later than September 30, 2025 to establish a strategy and timeline. Initial target for systems and training completion: March 31, 2026 (before the 2026–2027 hiring season).

Recommendation 2.5

The human resources department should develop an accountability report to ensure administrators adhere to district hiring policies, specifically related to verifying documentation of eligibility for hired individuals.

District Response: The district concurs.

Contact: Dr. Mark Ernst, Superintendent mernst@tooeleschools.org (435) 833‑1900

What: The Superintendent, HR Director, and Assistant HR Director will create an accountability report for verifying eligibility documentation for new hires.

How: The Superintendent will meet with the HR team to determine the best course of action. The review will identify systems needing change and new measures to be instituted.

Documentation:

• Systems put in place

• Training modules

• Proper verification of eligibility documents

When: The Superintendent and HR team will meet no later than September 30, 2025. Initial target for systems and training completion: March 31, 2026.

Recommendation 2.6

The Tooele County School Board and its superintendent should develop an implementation plan and system of accountability for all departments to reverse the culture of policy noncompliance.

District Response: The district concurs that policy compliance among some employees can improve.

Contacts: Melissa Rich, Board President — mrich@tooeleschools.org — (702) 622‑5186 Dr. Mark Ernst, Superintendent — mernst@tooeleschools.org — (435) 833‑1900

What: A districtwide implementation plan and accountability system will be created to ensure all employees understand their responsibilities. The plan will follow current TCSD policies and procedures. If policy changes are needed, they will follow established procedures. The plan will maintain employee rights under federal, state, and district regulations.

How: The Board and Superintendent will determine the best course of action. The review will identify systems needing change and new measures to be instituted.

Documentation:

• The implementation plan

• Accountability system

• Training materials

When: Board leadership and the Superintendent will meet no later than September 16, 2025 to determine a timeline. A concrete implementation date will be set after defining project scope. Initial target for full implementation: April 1, 2026.

Chapter 3 Responses

Recommendation 3.1

Tooele County School District should align the leadership academy training to school governance best practices.

District Response: The district concurs.

Contact: Dr. Jeffrey D. Hamm, Assistant Superintendent jhamm@tooeleschools.org (435) 833‑1900

What: TCSD is already in the process of aligning next year’s leadership academy schedule with Utah’s leadership standards. Leadership topics will be explicitly aligned with the standards each month.

How: The district is refining next year’s leadership academy curriculum to align with Utah’s Standards for Educational Leadership. Assistant superintendents will continue attending area directors’ principal trainings at monthly leadership meetings, provisional principal meetings, and superintendent collaboration meetings.

Documentation:

• An annual schedule covering all eight months of leadership academy

• Dates, presenters, curriculum, and leadership standards covered

• A library of monthly presentations accessible throughout the year

When: Practices and procedures will be in place by August 1, 2025.

Recommendation 3.2

Tooele County School District should ensure that area directors are better involved in the leadership training academy.

District Response: The district concurs.

Contact: Dr. Jeffrey D. Hamm, Assistant Superintendent jhamm@tooeleschools.org (435) 833‑1900

What: The superintendency will collaborate with area directors and coordinate their principal trainings, including monthly district leadership meetings, provisional principal meetings, and superintendent meetings.

How: The superintendency will continue attending area directors’ principal trainings at monthly leadership meetings.

Documentation:

• An annual schedule for all eight months of leadership academy

• Dates, presenters, curriculum, and leadership standards covered

• A library of monthly presentations accessible throughout the year

When: Practices and procedures will be in place by August 1, 2025.

Recommendation 3.3

Tooele County School District should assess the area director role to create strategic guiding documents to focus and evaluate their work on principals’ growth as instructional leaders.

District Response: The district concurs.

Contact: Dr. Sarah Jarnagin, Area Director – Stansbury sjarnagin@tooeleschools.org (435) 833‑1900

What: District leadership affirms its commitment to aligning practices with the Principal Supervisor Performance Standards (University of Washington, District Leadership Design Lab). TCSD began this work in Fall 2023 but paused due to budget shortfalls. Despite leadership transitions, alignment efforts have strengthened this year.

How: Area directors have established their purpose with support from the superintendent. They leveraged collective expertise and Utah’s Educational Leadership Standards to develop a plan for cultivating knowledgeable, confident, and capable school leaders. Next steps include aligning practices to the purpose and synthesizing strategies during summer work sessions.

Documentation:

• Common documents used by all area directors

• Consistent tools for school visits, principal meetings, guiding documents, timelines, and goal setting

• Records showing visit frequency, discussion topics, and coaching time aligned to Utah’s Leadership Standards

When: Research and development of systems and a theory of action will occur June–July 2025. Implementation begins August 2025. Monthly informal self‑evaluations will occur throughout the year. A formal evaluation with the Superintendent will occur in May 2026.

Recommendation 3.4

After TCSD creates guiding documents, the superintendent should ensure, through regular performance evaluations, that area directors prioritize growing principals into exceptional instructional leaders.

District Response: The district concurs.

Contact: Dr. Mark Ernst, Superintendent mernst@tooeleschools.org (435) 833‑1900

What: The superintendent will strengthen principal leadership capacity by embedding robust evaluation processes for area directors and engaging in their instructional leadership work.

How:

• Collaborative creation of guiding documents

• Superintendent‑led feedback sessions and evaluations

• Professional development aligned with Principal Supervisor Performance Standards

• Ongoing monitoring and strategy adjustments

• Accountability measures aligned with leadership standards

Documentation:

• A formal evaluation process

• Monthly one‑on‑one feedback meetings

• An evaluation tool based on Principal Supervisor Performance Standards

• Principal feedback included in evaluations

When: Implementation of standards begins August 2025. Weekly meetings will incorporate aligned elements. Monthly individual meetings will review actions and alignment. A formal evaluation tool will be developed by September 30, 2025. The first full evaluation cycle will conclude in May 2026.

Recommendation 3.5

TCSD should coordinate the work of Teaching and Learning, Special Education, and Student Services through an assistant superintendent devoted to academics, ensuring Annual High Leverage Practices align with the Strategic Model.

District Response: The district concurs.

Contacts: Dr. Jeffrey D. Hamm, Assistant Superintendent — jhamm@tooeleschools.org Dr. Cody Reutzel, Executive Director of Teaching & Learning — creutzel@tooeleschools.org (435) 833‑1900

What: Assistant superintendents will collaborate with executive staff to develop Annual High Leverage Practices aligned to the Strategic Model. Final approval will be provided by the superintendent and assistant superintendents.

Documentation: A published document recording:

• Annual High Leverage Practices

• Implementation strategies

• Explicit alignment to the Strategic Model for the next three years.

When: Practices, strategies, and alignment documents will be developed by October 1, 2025.

Recommendation 3.6

The Departments of Special Education and Student Services should adopt the same implementation strategy for their Annual High Leverage Practices as the Department of Teaching and Learning.

District Response: The district concurs.

Contacts: Dr. Jeffrey D. Hamm — jhamm@tooeleschools.org Dr. Cody Reutzel — creutzel@tooeleschools.org (435) 833‑1900

What: Special Education and Student Services will adopt an implementation approach mirroring Teaching & Learning’s strategy.

How: The superintendency will collaborate with executive staff to develop Annual High Leverage Practices and implementation strategies. Final approval will be provided by the superintendency.

Documentation: A published document recording Annual High Leverage Practices and implementation strategies for the next three years.

When: Practices and strategies will be developed by October 1, 2025.

Chapter 4 Responses

Recommendation 4.1

Tooele County School District should separately account for funding received from specific contracts based on student enrollment and ensure funds are not utilized or encumbered for expenses that span longer than the length of the contract, including termination clauses.

District Response: The district agrees with the finding and will comply if it enters another contract with an Education Service Provider (ESP). While the recommendation is sound in principle, achieving different outcomes may not be feasible unless revenue data is disaggregated by location—which it currently is not.

The district notes that the Utah State Board of Education (USBE) should assist LEAs in breaking out revenue by location. This would enhance transparency and enable more accurate financial assessments.

The audit noted that the “ability to review and assess the funds distinctly was limited.” TCSD clarifies that this limitation was not due to an inability to track expenditures by location, but because revenue data is not disaggregated. LEAs also do not have access to the funding formulas necessary to model revenue scenarios for individual schools.

Contact: Lark Reynolds, Business Administrator lreynolds@tooeleschools.org (435) 833‑1900

What: The district is committed to navigating current financial challenges and is implementing necessary changes over several years to adapt to reduced revenues following the departure of online students.

Beginning teacher salary increased significantly—from $33,142 in FY17 to $61,200 in FY24. Much of the previous surplus between revenues and expenditures was allocated to salary increases. The district anticipates that it will take multiple years to fully adjust to the new financial reality.

How: The district plans to strategically utilize reserves to manage ongoing costs until state and local revenues increase sufficiently. The goal is to maintain staffing levels and avoid unnecessary disruptions.

The district will continue to evaluate program efficiencies annually as part of the budgeting process to ensure long‑term sustainability.