MEMPHIS, Tenn. - Memphis-Shelby County Schools is roughly halfway through the 45-day window it has to deliver a corrective action plan responding to the state's forensic audit, and the district has not yet published one.
Tennessee Comptroller Jason Mumpower released the completed independent evaluation on July 8. Prepared by the accounting firm CliftonLarsonAllen, it runs to four volumes: an Internal Controls Assessment paired with an IT Cybersecurity Risk Assessment, a Forensic Audit, an investigation of the Herbert STEM Center at Whitehaven High School, and a TennCare evaluation.
The Internal Controls Assessment identified 98 observations covering governance, financial management, procurement, internal audit, compliance and operational controls, plus 51 observations on information technology and cybersecurity. The cybersecurity findings were not released publicly; the Comptroller's office cited Section 10-7-504(i) of the Tennessee Code, which treats such findings as confidential.
Chalkbeat Tennessee reported that the final audit identified more than $54 million in district spending over the review period as evidence of potential waste, fraud or abuse. The period examined was July 2021 through June 2024, when the district was led by former superintendents Joris Ray and Toni Williams. Richmond became permanent superintendent in 2026.
These are findings about management and control failures. An audit observation is not a criminal charge, and no one has been charged with a crime arising from this review. The forensic audit also identified potential Open Meetings Act concerns involving email exchanges among board members and legal counsel outside publicly noticed meetings, on matters including superintendent searches, contract negotiations, compensation decisions and consulting engagements. The Whitehaven Herbert STEM Center investigation concluded that project expenditures were generally appropriate and supported.
Under the state's takeover law, Richmond has 45 days from the final report to identify the key issues it raises and present a corrective action plan to the board. Counting from July 8, that lands in the third week of August, days after the 2026-27 school year begins on August 3.
The district's own board resolution, adopted March 31, sets the bar for what that plan has to contain. According to board meeting documents, the corrective action plan must include a clear description of each finding and its root causes; specific, measurable, actionable, timebound and sustainable corrective measures with realistic completion dates and incremental milestones; assigned department leads and named individuals responsible for implementation; key performance indicators to measure incremental improvement; and specific internal controls to prevent recurrence.
At this week's board meeting, Richmond told members that further improvements are coming to internal controls, procurement, human resources and cybersecurity processes. He has said the district is working toward a final report on how it is addressing the audit's findings and maintains an online dashboard tracking progress.
Richmond has publicly disputed how the audit has been characterized rather than the underlying transactions. In a letter following the release, he focused on the report's terminology, the scale of district operations, corrective work already underway, and his argument that the controversy should not overshadow academic results, citing four consecutive years of the state's highest academic-growth rating. His letter did not challenge the auditors' classification of individual transactions or identify which dollar figures the district believes are wrong.
All of this is happening while the state's takeover of the district is paused. On July 1, the day the appointed oversight board was to assume control, U.S. District Judge Waverly D. Crenshaw Jr. ordered that the parties maintain the status quo as to Public Chapter 1057 pending the court's consideration and decision on the plaintiffs' motion for injunctive relief. That order remains in effect. It came in a suit filed by Shelby County Government, MSCS, the elected school board and the Shelby County Board of Commissioners challenging the takeover law under the federal and state constitutions.
The pause is being contested. On July 14, members of the state-appointed Educational Oversight Board moved to dissolve the July 1 order and separately moved to dismiss the case for lack of jurisdiction and failure to state a claim. Plaintiffs responded July 23, and reply briefs were due July 27. Plaintiffs told the court they intended to file their motion for a preliminary injunction by July 27. A status conference before Magistrate Judge Jeffery S. Frensley is set for July 31.
Why It Matters for Memphis
Two billion dollars a year moves through this district. The audit did not conclude that the money vanished. It concluded that the systems for tracking, approving and documenting it were weak enough that the district could not always demonstrate where it went, and that repeated document requests went unfilled during the review itself.
That is the problem a corrective action plan exists to fix, and it is fixable. But only if the plan is specific. The difference between a district that has addressed an audit and one that has announced it will address an audit is measured in exactly the things the board's own resolution requires: named owners, dated milestones, and metrics someone can check later.
There is also a live political stake. The audit is the state's central justification for the takeover now sitting in front of a federal judge. A thorough, specific, on-time corrective plan is the district's strongest argument that outside control is unnecessary. A vague one hands the state its case.
Accountability Watch
- Who is accountable: Memphis-Shelby County Schools Superintendent Roderick Richmond
- What is pending: A corrective action plan responding to the state forensic audit, meeting the five requirements the MSCS board adopted in its March 31, 2026 resolution
- When: 45 days from the July 8, 2026 final report, which lands in the third week of August 2026
- Status: Not yet presented as of July 27, 2026
- How to verify: MSCS board agendas and packets on BoardDocs, the district's public audit-response dashboard, and the Comptroller's report page at comptroller.tn.gov









