ST. LOUIS — A report looking into the Saint Louis Public Schools shows the former superintendent spent thousands of dollars on questionable credit card charges that appear to violate policy. 

The audit comes after the previous superintendent, Dr. Keisha Scarlett, had her contract terminated by the Board of Education over questions about her hiring and spending practices.  

The report found $26,500 in questionable charges on cards issued to Scarlett for items like charcuterie boards, Edible Arrangements, Massage Envy, church gala, donation to the Missouri Botanical Garden, among others. 

Scarlett also was incurring automobile charges on her district card while receiving an $800 monthly vehicle allowance, according to the report.

The audit also looked at hiring practices. It points out $146,000 was spent on temporary contracts for newly hired chiefs and cabinet members for work prior to their “official” start dates.

Also, she authorized retroactive payments to eight chiefs and deputies totaling $94,801, according to the report. 

The report by Armanino LLP was made available online Tuesday. 

"Several of the issues noted during our assessment were due to the limited level of oversight related to the Superintendent's position," the audit states. "Due to the level of authority inherent in the Superintendent’s position, policy violations can occur, but not be brought to the Board’s attention due to the fear of possible retaliation."

In response to the findings, a statement from Scarlett’s legal team says the investigation was conducted “secretly, blatantly violating proper standards for independence and reliability.” 

It claims the report is biased and lacks credibility because she was not informed of the investigation or of the allegations against her, was not asked any questions or interviewed and was not given the chance to provide documentation.

“The Board of Education used this sham investigation to unlawfully terminate Dr. Scarlett, while intentionally excluding her from the process,” the statement reads. 

“The Board had already decided to terminate Dr. Scarlett and then after-the-fact conducted a sham investigation to justify their decision. She was never informed of its results and never provided with a copy of the report. Dr. Scarlett learned that the investigation had concluded through the media.”

As of Tuesday, Scarlett has not reviewed the report, according to her legal team.

Below are some of the finding in the 50-page report regarding the hiring practices and policy violations from July 2023 to August 2024. 

During her transition period, Scarlett incurred travel expenses totaling $4,820, however, no evidence was found that reimbursement was approved by the Board. Her employment contract required approval by the Board prior to the reimbursement.

The report states that Scarlett appears to have implemented a new salary structure without Board approval, which included additional salary increases for cabinet members “in excess of the amounts set forth in the compensation study.”

Before Scarlett began her role as superintendent for SLPS, the existing, approved salary range for chiefs were between $84,254.61-$185,961, with an average chief salary of $166,469. After she started, the newly hired chief of schools and chief of staff were paid $185,961, “significantly” more than existing chiefs.

Chief salary increases were entered into the system in January 2024, with an effective date of Dec. 16, 2023, according to the report. Salaries of ten chiefs were increased to $194,000 at the time, with the goal of increasing them to $200,000 in July 2024, which followed the implementation of 3% district-wide raises. The salaries for four deputy chiefs were increased to $175,000–$182,000. Two newly hired chiefs and two promoted deputies also received the higher salaries

Five out of eight sole source/emergency agreements more than $50,000, which were approved by the Board during open or closed sessions. However, the contract with Impact Educational that totaled $234,000 was not approved by the Board.

The report states that the contract was a walk-on to the November 2023 agenda, but it was removed by the Board and was not resubmitted to the Board by district leadership.

However, Scarlett signed the agreement and the full amount of the contract was invoiced and paid.

Sponsored Visa submissions by SLPS were completed for two employees without Board approval, according to the report. The district made efforts to assist the two employees in obtaining work Visas, and in doing so, the district promoted them to positions that would potentially help them to qualify for the Visas.

The report states that Scarlett charged vehicle expenses on her superintendent card and superintendent department card while also receiving a monthly vehicle allowance of $800 or when a district car was issued to her. There are questionable charges on those credit cards, totaling approximately $1,700.

There were questionable charges across all four cards that totaled approximately $34,000 with about $26,500 associated with the individual card issued to Scarlett, said the report. Some of the “unusual credit card transactions” that appear to be violations include flowers and Edible Arrangement gifts for Board of Ed members and district employees, furniture from Ikea and Wayfair and 22 meal purchases totaling $14,901 during retreats and with consultants. 

The report explains card policy states it can not be used to purchase meals, conference registrations and gifts. It also points out that it should never be used for personal purposes even if the cardholder plans on reimbursing the district.

The report states that Scarlett used three company credit cards for prohibited traveling expenses, totaling $12,600, with about $11,500 of that amount associated with the individual card issued to her. She also exceeded lodging expense limits by $423. Scarlett also charged meals to a company credit card while receiving a meal per diem of $50 per day while traveling.

There are questionable transactions on two company credit cards of prohibited or restricted non-reimbursable travel expenses, totaling approximately $19,500, with about $17,000 of that amount associated with the individual card issued to Scarlett. The policy prohibits or restricts certain charges such as expenses incurred by non-employees, internet access fees, tips/gratuities, travel to meetings, unapproved purchases, etc.

Policy notes that approval from the superintendent is required for traveling to conferences held outside the U.S. The report states there was an international delegation to Japan purchase in May 2024, totaling about $10,000 on a company credit card. Scarlett signed the travel form, however, there is no date on the form to confirm if it was approved before the trip.

The Board of Education with Interim Superintendent Dr. Borishade is working to implement corrective action and policy changes as recommended in the report. 

Some of those changes include:

• Hiring an internal audit and compliance director by the end of 2024. The district previously had a director, but the position was vacant.
• Adopting a revised finance policy, clarifying that the internal audit function will be directed by the BOE’s audit committee in January. The Board and superintendent will undergo annual training on the district’s travel and procurement procedures.
• Consulting with outside legal counsel to update its whistleblower policy and procedures.
• Hiring a full-time executive assistant to the BOE. The position will be solely assigned to duties relating to the operations of the BOE.
• The Board will use the annual superintendent evaluation process to prioritize communication and culture as goals by the superintendent.