JCPS Response To Transportation Audit

Administrative Offices
VanHoose Education Center

P.O. Box 34020
Louisville, KY 40232-4020
(502) 485-3011
MEMORANDUM
TO: Members of the Jefferson County Board of Education; Members of ARMAC
FROM: Marty Pollio, EdD
CC: Kevin C. Brown, General Counsel; Katy DeFerrari, Chief of Staff; Rob Fulk,
Chief Operations Officer
SUBJECT: Management Response to Phase 1 Transportation Audit by Prismatic Services
DATE: May 21, 2024
As you are aware, Jefferson County Public Schools (JCPS) contracted with Prismatic Services in October
2023 to undertake an audit of the transportation activities of August 9, 2023 (Phase 1) and the District
transportation program (Phase 2). At the Board meeting held on March 29, 2024, Prismatic Services made a
presentation to the Board regarding Phase 1 of the audit, and submitted the Phase 1 report, entitled, School
District of Jefferson County Public Schools: An Assessment of the Transportation Program and the
Transportation Activities of August 9, 2023.
Attached please find the JCPS Management Response to the Phase 1 Audit report and the Prismatic
presentation to the Board. In addition to providing responses to the specific findings in the written report,
this Management Response offers responses to comments made by Prismatic leadership at the March 29,
2024 meeting in response to Board member questions.
JCPS leadership agrees with most of the findings of the written Phase 1 report and this Management Report
provides details regarding actions that have been taken or are planned by the District to address those
findings.
Importantly, the Management Response also provides valuable context and additional in-depth details
regarding issues raised by Board members in their questions to Prismatic. In so doing, the Management
Response seeks to correct several erroneous assertions made by Prismatic, and clarifies certain incomplete,
inaccurate, uninformed, or misleading representations of facts made by Prismatic in their comments to the
Board.
As was true with all of the many audits that have been conducted on JCPS over the last seven years, I
welcome fact-based critical analyses of District systems and processes, and the District always strives to
use the results to improve how we serve the children and families of Jefferson County. That requires a
willingness to forthrightly recognize both strengths and areas for improvement based on a rigorous analysis
of full and accurate findings of fact. It also requires a willingness by myself and the Board to use that
information to make hard choices in response to the challenges we face. This Management Response is part
of the District's ongoing effort to support those outcomes.
Management Response - PRISMATIC Audit, Phase I
2-2 X Agree Disagree

If agree X In progress or Complete
Develop systematic procedures for Communication and collaboration between departments

related to school choice and schedule on-going reviews of school choice zones and
boundaries with the district transportation department to ensure students receive
transportation services to their choice schools as appropriate.
Response We agree with the desire to improve communication and collaboration. To do

so, we intend to improve our documentation of processes, expand use project
management tools, clarify key metrics and critical to quality indicators, develop
service level agreements between departments, clarify project sponsors and
RACI (responsible, accountable, consulted, and informed) assignments, and
ensure that all stakeholders - especially internal stakeholders - are all fully
engaged and informed. To ensure focus on all these points we will be hiring a
Program/Project manager (Executive Director Special Projects) to coordinate
key initiatives and ensure alignment across responsible staff and transparency
to initiatives sponsors.
The Executive Director Special Projects will oversee five major committees and
their work to establish a successful start to school for 2024-25. These five
committees are: First Day Team, Student Enrollment Team, School Support
Team, Staff Support Team, and the Family Support team. Each team will have
representation from all divisions on Cabinet, as well as additional
representation from relevant divisions and staff members specifically related to
the work of the team. All teams will have at least one Cabinet representative,
assistant superintendent, and executive administrator as standing members.
Teams will meet regularly, keep agendas and minutes, and be required to
house all related documents on a central platform. All teams will have a work
plan, timeline, and scope of work. While this recommendation deals specifically
with transportation, boundaries, and Choice Zone, this model will be used for
all major projects and implementations moving forward.
The ED Special Projects position has been advertised. The job advertisement
is advertised, the Chief of Staff will, as hiring manager, move forward with the
selection process. The Chief of Staff will be collecting division representatives
for the five teams from each Chief over the next two weeks.
1

If agree In progress or X Complete
Assign default schools to students who do not complete a school choice application by the
established deadline.
Response
We believe that it is critically important to honor the commitment made to
Choice Zone families to choose either a school closer-to-home or a farther-
away-school. We believe we can do that and simultaneously improve routing
efficiency. The School Choice Department did an extraordinary job
communication with affected families, resulting in close to 90% of affected
students submitting an application during for the application period (90% of
elementary students; 86% of middle and high school students). We believe that
that positive result can be achieved in future years.
We propose that the relatively small number of affected Choice Zone Students
who do not meet the application deadline be permitted to use the transfer
process to choose their close-to-home school or their farther-from-home school
without consideration of capacity and with transportation provided, thus
honoring our commitment.
Simultaneously, that relatively small number of Choice Zone students who do

not submit a timely application could be provided an internal default
assignment at their close-to-home school for routing purposes, since we know
that a relatively high percentage of Choice Zone families choose the close-to-
home school option. As students in the Choice Zone complete the application
after the deadline, school assignment and routing would be changed. This will
increase the efficiency of the back-end routing function by allowing it to occur
earlier during the routing season, while maintaining our commitment to families.
This approach aligns with our commitment to honoring the guaranteed choice
for Choice Zone families outlined in the School Choice plan approved in June
2022. The plan's emphasis on empowering families to choose between close-
to-home or far-away schools underscores our commitment to community
engagement and building trust.
2

Review options for adjusting SST for 2024-25
Response
We are reviewing School Start Times (SSTs) for 2024-25. Our priority is
maximizing transportation efficiency and then reducing the number of SSTs
and as much as possible using the optimal later high school start times. All
these goals have impacts across stakeholders.
It is important to note that SST changes impact several other areas, including:
student assignment, human resources, JCPS families, and school-based staff.
With the board decision on 4-10-24, the Transportation Department now knows
what routes we will be transporting for 2024-25. The Schools Division and
Operations Division met on 3-20-24 to review current start times, and the
Schools Division will recommend changes. We met again with the Schools
Division on 4-11-24 after reviewing these recommendations, and the
Superintendent’s recommendations.
We have been given the criteria for returning to geographic routes, condensing
start times to 3 peaks, and mirroring as much as possible. The current start
times (2023-24) were not constructed for geographic regions. We have
reviewed the feedback and our criteria and have created seven different
options for start times that the Superintendent reviewed. Our focus in
reviewing SSTs was efficiency, from the standpoint of on-time service; as many
mirrored routes as possible; as many geographic regions for bus drivers as
possible, to reduce driving time and increase efficiency for each driver; and
consolidating the start times serving a smaller number of students/schools into
our three peaks. As set forth below, all of these parameters are in accordance
with the assessment recommendations.
In addition, we are focused on moving as many of the elementary schools to

the 7:40 time slot as possible and moving secondary schools to 8:40 or later.
We will be limited in our flexibility to do this for the 2024-25 school year as the
timeline we are working under limits our implementation time, taking into
account the necessary work of School Choice Department, Human Resources
Division, and the needs of our community. We presented the various options to
the Superintendent for consideration the week of 4-22-24. The Board approved
new start times on 5-7-24.
All possible solutions for 2024-25 were built with only 3 peak start times.
3

Review options for moving schools on mini-tier start times to a major tier start time.
Response
We reviewed School Start Times (SSTs) for 2024-25, and plan to consolidate
as much as possible mini-tier start times into our three peaks, reducing
unnecessary complexity of our routing schedules. It is important to note that
SST changes impact several other areas, including student assignment,
human resources, JCPS families and school-based staff. The Schools Division
and Operations Division met on 3-20-24 to review current start times and the
Schools Division recommended changes. We met again with the Schools
Division on 4-11-24 after reviewing these recommendations, and the
Superintendent’s recommendations. With the Board decision on 4-10-24, the
Transportation Department now knows what routes we will be transporting for
2024-25.
We were given the criteria for returning to geographic routes, condensing start
times to 3 peaks, mirroring as much as possible. The current start times (2023-
24) were not constructed for geographic regions. We have reviewed the
feedback and our criteria and have created seven different options for start
times that the Superintendent will review. Our focus in reviewing SSTs was
efficiency, from the standpoint of on-time service; as many mirrored routes as
possible; as many geographic regions for bus drivers as possible, to reduce
driving time and increase efficiency for each driver; and consolidating the start
times serving a smaller number of students/schools into our three peaks. As
set forth below, all of these parameters are in accordance with the assessment
recommendations.
In addition, we were focused on moving as many of the elementary schools to

the 7:40 time slot as possible and moving secondary schools to 8:40 or later.
We will be limited in our flexibility to do this for the 2024-25 school year as the
timeline we are working under limits our implementation time, taking into
account the necessary work of the School Choice Department, Human
Resources Division, and the needs of our community. We presented the
various options to the superintendent for consideration the week of 4-19-24.
All possible solutions for 2024-25 are built with only 3 peak start times.
4

Review options for adjusting all secondary schools to the 8:40 am to later SST for 2024-25
Response
We have communicated to principals since January that any transportation
change for 2024-25 outside of keeping our current system will require adjusting
start times. Our Board approved School Start Times on May 7th. Additionally,
the Board recommended that we provide another school start time plan that
would achieve this measure. They would like it presented to them by
December 1, 2024. We believe moving high school start times to 9:40 will
require substantial planning, but it is possible for 25-26. We are exploring that
option.

Re-establish and adhere to an annual routing timeline.
Response
We agree and have established an annual routing timeline. We have hired a
routing team that bases their work on adhering to the timeline. Changes to the
timeline have been inevitable given project issues and challenges .
In January of 2024 the board approved job descriptions and organizational

chart changes to create a dedicated routing team for the Transportation
Department. This routing team consists of an assistant director, two routing
coordinators, two GIS specialists, and a data management technician. We
have moved aggressively in the hiring of these positions and are pleased to
report that the assistant director started on 3-22-24, the GIS specialists on 4-1-
24, and the two routing coordinators had started previously started. This puts
us in a great position for the 2024-25 routing season.
The Transportation Department began a review of the routing timeline in

December 2023. Part of the initial work of the routing team is to create an
updated routing timeline moving forward. We have solicited several examples
from Council of the Great City Schools (CGCS) districts that the Transportation
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Department has analyzed. As we route (March to July) for 2024-25, the routing
team will build their timeline concurrently. We are already a few weeks behind
schedule, and any pause in implementing the approved plan would have
serious consequences to stay on track with our routing timeline.

Rework AR routes.
Response
The routing team will be doing a full re-route of the district during the 2024-25
routing season (March to July). Our routing team will be using our internal
routing process for the 2024-25 season. We will route all of our buses. We are
tasked with going back to mirrored runs and geographic areas as much as
possible to improve efficiency.

Create more effective communications processes around routing.
Response
The primary driver of organizational communication with routing will be the
establishment of our routing team.
There will be a weekly "transportation status meeting" to include the routing

team, Transportation/Operations leadership, and the Executive Director
Special Projects. A summary report will be distributed thereafter to the
Superintendent and pertinent Cabinet members. The timeline will have key
milestones and process metrics which will be reported on in terms of green,
yellow, red assessment of readiness as part of the weekly sessions and
distributed notes.
A risk and issue log will be part of the communication strategy. Any
stakeholder can add to the log.
Changes to our routing procedure for 2024-25
● Route entirely in-house through the routing team

● Standardize routing timeline for future use
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● Establish a pause period for routing, to be determined near the end of

the summer to assure we have a cohesive route plan to start the year
(mirroring most large districts)
● Conduct re-integration of mirroring and geographic regions for bus
drivers
● Build starting bus loads at 44 students as a baseline
● Remove the ability for schools to add stops (a cause of bus overload)
and have the routing team be responsible for adding stops
● Have regular meetings with our union partners to update them on
changes to routing/ transportation timelines
● Use a longer practice “dry run” period for bus drivers in the summer of
2024 to prepare for the year
In addition, the Superintendent has committed to a wholescale evaluation of

first day procedures. These meetings began in January 2024, which include
multiple divisions reviewing first day procedures and creating new procedures
as we change routing processes. The results of the evaluation will inform the
work of the five committees under the Executive Director of Special Projects.

Adopt an integrated routing, GPS, and camera system.
Response
We are well ahead of this recommendation. We have routing software with
integrated GPS on tablets in each bus. The camera system will monitor
activities on the bus and provide live video.
Samsara and Prologic are two vendors who will be installing cameras and
tablets on our buses. This technology was completed by 4-8-24 . Installation
began on 3-19-24. We are providing this technology for 725 vehicles, with the
vast majority being buses, but also it will be installed on our ‘white fleet” (vans).
This will give us live information and video, which we have not had in the past
and provide route assistance for drivers. This will allow drivers to have updated
GPS, and routes populated to their tablets when the buses are not in motion.
Our camera system will be a modern camera system that has real-time access.
5-1 Agree X Disagree

If agree In progress or Complete
Improve the district’s Professional Services Contracts Administration by formally designating a
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contract administrator or contract manager for each contract and develop specific
responsibilities for the position.
Response
Every contract without exception is presented by a Cabinet member or the
Superintendent for Board approval. The intent is to inform the Board who is
procuring the services of the contracts and who will be accountable for contract
completion, similar to the auditor’s definition of a contract administrator. After
the Board approves a contract, the school or department procuring the
contractor’s services creates a requisition that aligns to the approved contract.
The requisition generally lists the name of the individual procuring and
overseeing the services of the contractor. Often, this field will read two names:
Requisitioner/administrator in charge of the contract. This administrator listed
on the requisition aligns with the auditor’s description of contract manager.
We believe JCPS already complies with the auditor’s recommendation, but we

will review this with our Purchasing Department to ensure this is being done
consistently, as it was for the contracts reviewed during this audit.

Improve the timing of payments in Professional Services Contracts and Data Privacy
Agreements to help ensure the district receives satisfactory services before making payments
to vendors.
Response
We agree that advance payments should be avoided to the greatest extent
possible. Although we believe these are uncommon, we will review our
practices to minimize them in the future.
We agree and will require contracts to have specific milestones with

acceptance standards that must be met prior to payments. The Finance
Division will require the contract administrator sign off on acceptance standards
prior to authorizing payment. Any exceptions will require cabinet-level approval
including that of the CFO.

Improve Professional Services Contract document’s scope of services to help ensure the
district receives the services that it needs and is paying for.
Response While we believe many of the detailed services described would be more
appropriately included in an addendum to the contract rather than the face of
8
the contract itself, model procurement requires the full description of the scope
of services, as the auditor describes.
We agree with the auditor and will emphasize this clarification in contract
training sessions moving forward.

Improve the district process for using Sole Source contracting.
Response We agree with this recommendation and have already begun implementing an
improved process. Under the new process, the vendor sole source declaration
will be replaced with a JCPS employee documenting their efforts to find
competitive vendors and their rationale for determining that the vendor is the
sole source.

Include representatives of all departments in major initiative planning.
Response As mentioned in response to 2-2, the new Executive Director Special Projects
will be required to have a minimum of one representative from each District
division on each work team developed for a project implementation. These
representatives WILL NOT take the place of other staff from relevant divisions
related to the work of the actual project and scope.
All teams will be required to meet regularly, keep agendas and minutes, and be
required to house all related documents on a central platform. All teams will
have a work plan, timeline, and scope of work.
The Superintendent and Chief of Staff will designate major initiatives for such
planning, including one-time and annual efforts (such as first day). The
determination will be based on ongoing risk management reviews of all
initiatives and change efforts, using the level of potential stakeholder (e.g.
student, teacher, etc.) disruption from project failure/partial failure as the
determinant of what constitutes a major initiative.
9

Provide better and documented information to the school board and the public regarding
major initiatives.
Response The Superintendent and appropriate Cabinet members, supported by the new
Executive Director Special Projects, will provide updates to key stakeholders,
including the Board and Audit and Risk Management Advisory (ARMAC),
certified and classified employee representatives, and the Advisory Committee
on Racial Equity. PowerPoints that summarize decisions may be supplemented
with separate read-aheads with options and data analytics supporting the
recommended decision.
Additionally, centralized documents, plans, timelines, etc., will be available and

shared with the Board and public throughout a project’s implementation. The
Communications Division and pertinent departments will work together to
ensure that the public receives access to that information and has the
opportunity to provide feedback.

Evaluate the potential for implementing greater depot use.
Response
Under the approved plan, we will be transporting magnet school students to
and from Central High School and Western High School. We are committed to
using our routing team to effectively utilize the depots required. Much of the
inefficient use of the depots has occurred because the geographic location of
students on pickup was not always aligned with their destination school. As we
rework the depots during the summer 2024-25 reroute, we will focus on
reduction of run time and optimal bus loading.
10
Responses related to items outside the audit recommendations:
“We had one very smart district last year figure out how much all the other counties around
them were paying and gave them a dollar more … and sent out flyers.”
Response JCPS has pursued a strategy like this for several years, and much more
aggressively than the district referenced in this comment. Our starting bus
driver wage is roughly $6 an hour more than Hardin County, $5 than Bullitt
County, $3 than Fayette County, $5 more than Oldham County, $6 more than
Shelby County and all of our top end pay is considerably more than
surrounding counties. Our pay range for a starting bus driver of $22.87-$35.78
places us in the top of the Commonwealth of Kentucky in bus driver
compensation. When compared nationally, we are one of the top districts for
bus driver compensation. When compared to the local industry, our bus driver
wage is higher starting pay than comparable jobs at Amazon, Transforce,
American Distributing, FedEx, TARC, and Haverty’s Furniture. UPS
comparable role starts at $26.32, which we compete with by using the addition
of stipends for challenging runs and Early Childhood (ECH) runs.
Our comprehensive approach to bus driver recruitment and marketing has

made use of digital advertising since 2017 which includes embedded banner
ads on the local and national industry websites and social media campaigns.
Additionally, we have utilized targeted mailings, yard signs, focused job fairs,
bus driver highlights (employee spotlights), and the attendance bonus. We
began making use of IP targeting and highly technical marketing techniques in
2022. Those methods are still being used today and continue to result in new
bus driver applications.
“The reworking of the vendor provided routes could have been ongoing since last August, or
they could have been ongoing since November when in conversations with your staff we
made those suggestions.”
Response This work has been ongoing since August 2023, and the work has continued
since the COO and Transportation Director last spoke with Prismatic staff in
November. Since August 2023 our transportation specialists, compound
coordinators, and now the routing team work daily on consolidating and
trimming routes where possible. This year started with the intention of having
roughly 650 routes. We currently stand at 568 routes as of the response in this
document. The Transportation Department has cut, consolidated, and trimmed
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where it is possible. It is not possible to do a full re-route during the middle of

the year while schools are in session. That is the work of March 1- June 30
during the routing season for 2024-25. It is remarkable that our Transportation
Department has managed to trim down to under 570 routes to make as
workable a solution as possible during this school year.
“The district used to depot 70% of their students and should utilize that more.”
Response This is incorrect. The district has never depoted 70% of our students. The last
percentage of depot usage is from 2021-22 when roughly 15% of students
transported. The usage of depots is to exchange students from various runs to
direct runs to magnet, traditional, and A5 schools. We do not agree with the
recommendation to depot resides school students within a geographic area
and we will not pursue this recommendation.
“There are contractors nationwide that provide the bus and the driver.” We use Miller for as
many routes as possible. “Fine, ask for other contractors.”
Response Miller is the only known bus contractor in Louisville of any volume. They have
partnered with JCPS for years to help supplement our transportation. We have
asked Miller to pick up more routes for the district, but due to prior obligations
for parochial schools, they do not have any additional capacity on a day in and
day out basis. The closest large contractor we know of is in Indianapolis. We
have talked with them, and currently they do not have the infrastructure,
personnel, or licensing to expand to Kentucky. We partner with Everdriven for
special education van runs and will continue to do so. We continue to explore
contracting options, but none are quick fix solutions.
“We provided basic recommendations to the district in November.”
Response These recommendations included “trim around the edges” as their primary
recommendation. As stated previously:
Since August 2023 our transportation specialists, compound coordinators, and

now the routing team work daily on consolidating and trimming routes where
possible. This year started with the intention of roughly having 650 routes. We
currently stand at 568 routes as of the response in this document. The
Transportation Department has cut, consolidated, and trimmed where it is
possible. It is not possible to do a full re-route during the middle of the year
while schools are in session. That is the work of March 1- June 30 during the
routing season for 2024-25. It is remarkable that our Transportation
Department has managed to trim down to under 570 routes to make as
workable a solution as possible this year.
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Additionally, it must be noted that Prismatic’s “basic recommendations”

provided in November 2023 were not specific and consisted of general,
generic statements that offered no meaningful feedback to the Transportation
Department. When pressed for more specific recommendations, the
Operations Division was told to wait for the phase I report.
“You’re only short 17 drivers”.
Response This statement is misleading and shows a fundamental lack of understanding

of the driver shortage JCPS is facing.
568 daily routes at peak.

- 552 drivers
- 52 absent daily
- 500 daily available drivers.
- 68 routes uncovered = 68 drivers short
This equates to daily delays that clear the last bus at approximately 6:58 pm
and has in roughly 8 million lost instructional minutes for students thus far in
2023-24 school year, the predominance of which have been lost by the 19,000
Black and Brown students attending their resides schools. We project the loss
of instructional time to be approximately 12-13 million minutes by end of this
school year.
Our trend data has been consistently showing decreases in available bus
drivers since 2013, when where we had approximately 1100 drivers. We now
stand in the 550 bus driver range.
“How many drivers were hired as a result of the February Blitz… How many more blitz[s]
should happen to get the number of drivers you need?”
Response The district was prepared to provide an update on the results of the blitz at the
Board meeting on 3/26/2024. We also were prepared to share with the Board
that we would hold additional blitz opportunities. The next blitz was held on
Saturday 4/14/24. Another bus driver blitz is scheduled for Saturday, 6-1-24.
We previously shared with the Board that the bus driver hiring process is very
involved and takes time due to federal requirements in place for the school
bus driver position.
The blue tracker shows a summary of the applicants we have tracked from the
2/10/24 Blitz. It should be noted that we continue to track all other bus driver
applicants. Note that the Blitz, which had 171 attendees and 97 applicants,
has resulted in 10 drivers eligible for hire. We have hired four additional
drivers through normal means during this time.
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The 4/13/24 blitz results are provided in the orange tracker below.
“We saw buses with only 20 students”
Response The Prismatic auditor did not indicate where or when this occurred. This can
be a common occurrence and is most often attributed to:
1- It is a small magnet run from a far part of the county on route to a depot.
2- It is a combined run (such as Stonestreet/ Layne) that has dropped off 40
Stonestreet students on route to Layne, where it drops off 20 students.
It is difficult to respond to a specific observation without knowing the where,

and when. In this case, using it as a one-off example is damaging to the
overall understanding of our transportation system by the Board and
community, since it was provided as anecdotal evidence without context and
unsupported with any meaningful or actionable data.
“Transportation needs to be a part of the solution.”
Response The Prismatic document clearly references at several points that we are to
listen to the Transportation Department. Transportation Department leadership
has been in every discussion about the variety of solutions that have been
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proposed. Mr. Dobbs, or his next line of leadership, or bus compound

coordinators have been in every discussion as we have worked towards
solutions. We believe this recommendation is of primary importance, and has
been implemented prior to this audit, starting in October 2023.
The assertion that we can “trim around the edges” and take “a large swack” at the lost
instructional minutes
Response As stated previously:

This work has been ongoing since August 2023, and the work has continued
since the COO and Transportation Director last spoke with Prismatic staff in
November. Since August 2023 our transportation specialists, compound
coordinators, and now the routing team work daily on consolidating and
trimming routes where possible. This year started with the intention of having
roughly 650 routes. We currently stand at 568 routes as of the response in this
document. The Transportation Department has cut, consolidated, and trimmed
where it is possible. It is not possible to do a full re-route during the middle of
the year while schools are in session. That is the work of March 1- June 30
during the routing season for 2024-25. It is remarkable that our transportation
department has managed to trim down to under 570 routes to make as
workable a solution as possible during this school year.
“You have plenty of time….”
Response The auditor’s comment directly contradicts Recommendation 4.1 which

advises us to re-establish and adhere to a routing timeline. We concur with
this recommendation, and we have been working on implementing it since
December 2023.
Typically, our routing season starts at the beginning of March. The final
decision by the Board on 4/10/24 has put us several weeks behind.
For context it is important to understand why this routing season is extremely

complex:
1. We must re-route the entire district. This includes re-routing the

vendor-provided routes.
2. We have been tasked with returning to geographic regions, as school
start times are not aligned to this, it requires significant work with
school start times to return to geographic regions.
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3. We have been tasked with returning to mirroring routes. Currently

almost none of our routes mirror. This is an additional complexity to the
2024-25 routing season.
4. We must do all of this with significantly less previous data than other
routing seasons. This is because prior to this year, we had a different
student assignment plan. As we now have a new student assignment
plan, we must rebuild new routes, without the AlphaRoute solution.
Our Transportation Department has been clear on what they need. Further,
we agree we must adhere to a routing timeline. To have the best chance at a
successful opening day for 2024-25, the routing timeline must be in place and
adhered to.
For example, the available data seem to indicate that JCPS staff are not sufficiently sensitive
to the need to comply with state data retention requirements. These requirements are outlined
on the JCPS website, and they include the retention of emails
(https://www.jefferson.kyschools.us/node/2355). Nevertheless, there appears to be a lack of
adherence to retention requirements for emails. District employees are required to retain
some emails permanently while others are retained for a shorter period. Yet, when seeking
emails relevant to topics of conversation in interviews, several principals felt they were
missing emails from the July-August 2023 period. In interviews with central office staff,
Prismatic expected to be able to gather more email documentation than was ultimately
available. Overall, the consulting team concluded there was insufficient data for a
recommendation, as it was not possible to document the apparent lack of emails, without
being able to prove they had once existed. One possible alternative explanation is that the
emails never existed. This possibility was perhaps supported by a JCPS leader who stated
they felt encouraged to use cell phone texting instead of district email because texting is less
subject to open records requirements.
Response
All staff are aware of record retention requirements. However, there is no
overarching “email” record retention category. Instead, the retention period for
each individual email varies based on the content of the email itself. The
District Electronic Records Management working team found that rather than
failure to retain messages, the issue was more often that staff were over-
preserving emails, keeping them long past the timeframes listed in the
Records Retention Schedule.
It is difficult to respond to a “feeling” that there “should” have been more

emails, as there are no specifics offered. It is possible that the messages
exist, but that Prismatic requested them directly from the individual who
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referred to the message. For a variety of reasons, the staff may have had
difficulty locating a message that does in fact still exist and could have been
located if Prismatic had provided District Central Office staff with sufficient
information to identify the message at issue. As Prismatic noted, it is also
possible that these emails never existed at all. We communicate with our
principals via many different methods. It is possible that the unidentified staff
member was remembering a slide from a presentation at a Principals Meeting,
or a document provided via a Google page.
Finally, our staff are not encouraged to circumvent the Kentucky Open
Records Act. Staff are trained regarding the Kentucky Open Records Act to
assist the district in complying with its obligations and to remind staff of the
importance of being professional in all written communications.
In summary, our experience has been that email records are retained longer
than they should be, rather than being deleted prematurely, and to the extent
that the emails referenced did exist, it is likely an issue with the search itself,
rather than retention. If Prismatic could provide more details about the
communications that staff “felt” were missing, we have District-level
technology resources to locate those communications, if they exist.
Response We downloaded the county shapefiles for Jefferson County from our Jefferson
County GIS Consortium (LOJIC), and then downloaded the Anne Arundel
County shapefile from their county GIS agency.
 Prismatic appears to have used the total square mileage from
Wikipedia of 588 square miles, which includes 173 square miles of
water.
 We confirmed from the Anne Arundel County GIS shapefile that the
square mileage of land is 414.6 square miles:
17
 After analyzing the Jefferson County shapefile, the total square

mileage is 398.5 square miles, which includes the Ohio River. To be
fair, we subtracted the area of the Ohio River, which is 14.2 square
miles, resulting in 384.3 square miles of land:
18
Updated graphic:
See this Google Sheet for complete summary and additional

sources: https://docs.google.com/spreadsheets/d/1bBUGnwEXVJtE-
zWogJtCnIBDlugKNvIABf7aPo6MYjc/edit#gid=0
19

JCPS Response To Transportation Audit

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JCPS Response To Transportation Audit

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Administrative Offices

VanHoose Education Center

TO: Members of the Jefferson County Board of Education; Members of ARMAC

FROM: Marty Pollio, EdD

SUBJECT: Management Response to Phase 1 Transportation Audit by Prismatic Services

DATE: May 21, 2024

2-2 X Agree Disagree

Develop systematic procedures for Communication and collaboration between departments

Response We agree with the desire to improve communication and collaboration. To do

2-3 X Agree Disagree

Simultaneously, that relatively small number of Choice Zone students who do

3-1 X Agree Disagree

Review options for adjusting SST for 2024-25

In addition, we are focused on moving as many of the elementary schools to

3-2 X Agree Disagree

In addition, we were focused on moving as many of the elementary schools to

3-3 X Agree Disagree

4-1 X Agree Disagree

Re-establish and adhere to an annual routing timeline.

In January of 2024 the board approved job descriptions and organizational

The Transportation Department began a review of the routing timeline in

4-2 X Agree Disagree

4-3 X Agree Disagree

Create more effective communications processes around routing.

There will be a weekly "transportation status meeting" to include the routing

Changes to our routing procedure for 2024-25

● Route entirely in-house through the routing team

● Establish a pause period for routing, to be determined near the end of

In addition, the Superintendent has committed to a wholescale evaluation of

4-4 X Agree Disagree

Adopt an integrated routing, GPS, and camera system.

5-1 Agree X Disagree

Improve the district’s Professional Services Contracts Administration by formally designating a

We believe JCPS already complies with the auditor’s recommendation, but we

5-2 X Agree Disagree

We agree and will require contracts to have specific milestones with

5-3 X Agree Disagree

5-4 X Agree Disagree

Improve the district process for using Sole Source contracting.

6-1 X Agree Disagree

Include representatives of all departments in major initiative planning.

6-2 X Agree Disagree

Additionally, centralized documents, plans, timelines, etc., will be available and

6-3 X Agree Disagree

Evaluate the potential for implementing greater depot use.

Responses related to items outside the audit recommendations:

Our comprehensive approach to bus driver recruitment and marketing has

where it is possible. It is not possible to do a full re-route during the middle of

“We provided basic recommendations to the district in November.”

Since August 2023 our transportation specialists, compound coordinators, and

Additionally, it must be noted that Prismatic’s “basic recommendations”

“You’re only short 17 drivers”.

Response This statement is misleading and shows a fundamental lack of understanding

568 daily routes at peak.

“We saw buses with only 20 students”

It is difficult to respond to a specific observation without knowing the where,

“Transportation needs to be a part of the solution.”

proposed. Mr. Dobbs, or his next line of leadership, or bus compound

Response As stated previously:

“You have plenty of time….”

Response The auditor’s comment directly contradicts Recommendation 4.1 which

For context it is important to understand why this routing season is extremely

1. We must re-route the entire district. This includes re-routing the