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The ministry conducts compliance audits in key areas in which school boards receive funding under the Grants for Student Needs funding model.

Compliance Area Grant
Enrolment (Day School) Core component of the Pupil and School Foundation Grants, Pupil Accommodation Grant, Language Grant, Geographic Circumstances Grant, Special Education Grants, Transportation Grant, School Board Administration and Governance Grant, and Learning Opportunities Grant
English as a Second Language (ESL)
Programme d'appui aux nouveaux arrivants (PANA)
Core component of the Language Grant

Scope and Approach

The Financial Analysis and Accountability branch is responsible for planning, conducting and reporting on the compliance audits. The branch develops audit standards, tests and procedures with the assistance of school board staff and auditors from the Ministry of Finance and is also responsible for identifying and selecting boards for compliance audits.

The majority of boards for compliance audits are selected on a random basis, while a small number of boards are selected on the basis of 'field intelligence', which may involve a ministry evaluation of individual board reporting patterns and trends. Wherever possible, the four types of school boards (English, French, public and separate) are represented in the boards selected for audit.

Certain audits, such as enrolment, require selecting the schools to be visited. The initial sample size of schools selected is based on a provincial standard and depends on the number of elementary and secondary schools operated by the board. The testing of enrolment and English as a Second Language data for elementary schools may be conducted through either through desk audits or field visits.

Boards are notified at least one month before the start of the audit field work and are asked to identify a person who will be the board contact. Boards are advised of the audit period (board fiscal year) and of the schools, if any, that have been selected for visits. The board contact is encouraged to accompany ministry staff during the visits. Additional schools may be visited depending on audit findings.

An audit interview is scheduled with board staff before and after the audit fieldwork. All findings are discussed with board staff and a report is issued for each audit. Audit findings are shared with board staff for comments before the audit report is issued to the Director of the board. The report outlines the testing that has been conducted, the findings and any adjustments.

Audit adjustments often result in grant recoveries from boards or may involve additional grant payments to boards. Audit adjustments are based on audit test findings conducted in the audit period; however depending on the nature of the findings, other techniques such as expanding testing to prior years or prorating errors may be necessary.

Because future compliance is a key objective of the ministry audit process, the audit report provides a series of recommendations, if required, to address any area of non-compliance or possible improvements to board internal controls. Follow-up audits may be necessary to ensure that boards have made the necessary changes or improvements.

Enrolment Audits (Day School)

Ministry Requirements

Boards are required to record enrolment and maintain enrolment records according to the format prescribed by the ministry and according to the enrolment register instructions provided by the ministry. In addition, the legislated grants regulation stipulates how boards calculate average daily enrolment.

For more information:


The objectives of the enrolment audits and the compliance reviews is to ensure that the boards:

  • accurately record enrolment according to the ministry enrolment registers and the guidelines for elementary and secondary schools
  • accurately report enrolment values to the Ministry through OnSIS.
  • make the necessary changes in their enrolment recording and reporting based on findings and recommendations from the prior year's ministry audit.

Common Findings and Observations

  • Confirmed school level enrolment values, as reported to the ministry through OnSIS, do not equal values reported in the monthly summaries of the school year-end enrolment registers.
  • Pupils without valid medical reasons or attendance counsellor intervention are not removed from the register after 15 school days of consecutive absence.
  • Schools fail to take pupils off the register on the date the pupil retired or transferred.
  • Pupils that transferred or retired at the end of a semester are not removed from ministry registers due to a placeholder code that was improperly recorded on pupil timetables.
  • Period lengths in the school enrolment Student Information Systems do not correspond to the actual period lengths.
  • Common course codes are not included in the calculation of pupil full-time equivalency and as a result full-time pupils are incorrectly reported as part-time pupils.
  • Some schools are unable to produce enrolment registers and records to substantiate enrolment values reported to the ministry.
  • Schools fail to take SAL pupils off the register when they are no longer of compulsory school age.
  • In some cases pupils are identified as SAL and maintained on the register prior to approval of the SAL committee.
  • Schools fail to properly complete the biographical section of the Ontario Student Record (OSR) folder.
  • Pupils for whom boards may charge tuition fees are sometimes incorrectly reported as pupils of the board.
  • Pupils enrolled in Care and Treatment programs are not admitted and/or demitted from enrolment registers in accordance with ministry requirements.
  • School principals fail to demonstrate (by certifying) that they have reviewed for accuracy the enrolment values/data in enrolment registers at the end of the school year.
  • Pupils recorded in the enrolment registers as participating in a reciprocal educational exchange program do not satisfy ministry policy for a valid pupil exchange program.
  • Schools fail to retain, for audit purposes, the following for the current and the previous school year: 1) year-end full-time and part-time enrolment registers, 2) secondary pupil course timetables in effect on the count dates, 3) secondary pupil course change forms, 4) dated and stamped OSR request letters, 5) daily attendance reports, and 6) pupil registration/withdrawal forms.
  • Appropriate attendance procedures and accurate Daily Attendance Records are not established for pupils enrolled in secondary school alternative programs.
  • Appropriate admission procedures are not established to determine whether pupils should pay tuition fees.

English as a Second Language (ESL)/Programme d´┐Żappui aux nouveaux arrivants (PANA)

Ministry Requirements

English as a Second Language (ESL)

For funding purposes boards may claim the number of immigrant pupils, enrolled in their schools on October 31, who entered Canada for the first time during the last four years and were born in a country other than Great Britain, Ireland, the United States, Australia and New Zealand.

Programme d'appui aux nouveaux arrivants (PANA)

For funding purposes boards may claim the number of immigrant pupils, enrolled in their schools on October 31, who do not have Section 23 rights under the Canadian Charter of Rights and Freedoms, and who entered Canada for the first time during the last four years and were born in countries in which neither French nor English is the first language of a majority of the population; or they were born in countries in which a majority of the population speak a variety of French that is sufficiently different from the French used as the language of instruction in schools of the board.

For more information:


The objectives of the ESL/PANA compliance audits is to ensure that the boards selected for audit:

  • accurately report the number of immigrant pupils who entered Canada within the last four years from a qualifying country
  • retain immigration information in the pupil's OSR file to support the claims

Common Findings and Observations

  • Supporting documents confirming the pupil's first date of entry into Canada are not retained in the pupil's OSR file.
  • Schools incorrectly claim pupils not enrolled on October 31 of the current school year.
  • Schools report pupils who first entered Canada outside the 4 year qualifying period.
  • Schools fail to claim foreign exchange pupils, in a valid Education Exchange Program, for ESL/PANA funding.
  • Fee-paying pupils and pupils who should be fee-paying are incorrectly claimed.
  • Qualifying pupils are reported in the incorrect year.
  • Pupils from non-qualifying countries are incorrectly claimed.
  • School Internal records do not reconcile to the number of pupils claimed.

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