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Report Number: 2016-136

Abbreviations

School Violence Prevention
School Districts, County Offices of Education, and the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies

Responses to the Audit

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California Department of Education


August 11, 2017

Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Subject: School Violence Prevention – School Districts, County Offices of Education, and the
State Must Do More to Ensure That School Safety Plans Help Protect Students and
Staff During Emergencies, Audit Number 2016-136, dated August 2017

The California Department of Education (CDE) appreciates the opportunity to comment and provide proposed corrective actions for the recommendations outlined in the California State Auditor's (CSA) Audit Report No. 2016-136 titled: School Violence Prevention – School Districts, County Offices of Education, and the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies.

Recommendation 1

To ensure districts and county offices properly review and approve safety plans as required, CDE should provide the following additional guidance regarding district and county office responsibilities under state law:

Recommendation 2

To ensure districts, county offices, and schools receive guidance on a variety of safety issues, and to comply with state law, CDE and DOJ should resume their partnership activities, as required by state law. Further, the partnership should update the 2002 handbook, Safe Schools: A Planning Guide for Action, and distribute it to all districts and county offices. If CDE or DOJ determine they need additional funds to implement the legislative recommendations or to reestablish the partnership's activities, they should request those funds from the Legislature.

CDE's Comments and Corrective Actions

The CDE concurs with the recommendation. The CDE will initiate a meeting in 2017 with the DOJ to explore the possibility of resuming the School Law Enforcement Partnership (SLEP). However, funding for SLEP staffing and activities is no longer available and will need to be requested from the Legislature and received by the CDE, DOJ, and all county regions in order to ensure the success of resuming the program. In addition the CDE is researching costs for updating the 2002 handbook.

If you have any questions regarding the CDE's comments or corrective actions, please contact Kimberly A. Tarvin, Director, Audits and Investigations Division, by e-mail at ktarvin@cde.ca.gov.

Sincerely,


Michelle Zumot
Chief Deputy Superintendent of Public Instruction

MZ:kl




Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM CDE

To provide clarity and perspective, we are commenting on the response from CDE. The number below corresponds to the number we have placed in the margin of CDE’s response.

1

The letter that CDE references did not provide any guidance related to school building disaster plans. Further, when we discussed this matter with staff from CDE's coordinated school health and safety office, they noted that no guidance was available. As a result, we stand by our recommendation that CDE needs to provide guidance related to disaster plans. However, we are pleased to see that CDE will meet with other agencies to provide direction on school building disaster plans.



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California Department of Justice


August 11, 2017


Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Re: State Auditor's Report on School Violence Prevention

Dear Ms. Howle,

The Department of Justice (DOJ) has reviewed the California State Auditor's (CSA) draft report titled "Comprehensive School Safety Plans: School Districts, County Offices of Education, and the State Must Do More to Ensure that School Safety Plans Help Protect Students and Staff During Emergencies" and appreciates the opportunity to respond to the report.

The DOJ agrees with the stated importance of school districts and county offices to provide a safe, secure and peaceful environment to children attending California public schools. Under a previous Attorney General administration, the School Law Enforcement Partnership (SLEP) operated under the DOJ's Crime and Violence Prevention Center (CVPC). DOJ did not receive direct funding for these efforts; rather, staff and operating expenses were redirected from existing resources. Unfortunately, in FY 2008-09, the DOJ suffered significant General Fund budget reductions, a part of which included $4.681 million and 35.5 positions from the CVPC being abolished. This resulted in the complete dissolution of the CVPC program.

In response to the CSA's specific recommendations identified in the draft report, DOJ submits the following responses:

CSA Recommendation:

To ensure that districts, county offices, and schools receive guidance on a variety of safety issues, and to comply with state law, the California Department of Education (CDE) and DOJ should resume their partnership activities, as required by state law. Further, the partnership should update the 2002 handbook, Safe Schools: A Planning Guide for Action, and distribute copies to all districts and county offices. If CDE or DOJ determine the need for additional funds to implement the legislative recommendations or to reestablish the partnership's activities, they should request those funds from the Legislature.

DOJ Response:

The DOJ will work with CDE to review its' mandated activities and identify the resources needed to implement legislative recommendations or to reestablish partnership activities.

Current Attorney General Xavier Becerra recognizes the important mission of SLEP and looks forward to working with the Legislature on resource needs and CDE on program requirements. There is no more important task than keeping our children safe and the Attorney General stands ready to work with all partners to achieve this goal.

Sincerely,


CHRIS RYAN, Deputy Chief

Division of Operations


For XAVIER BECERRA

Attorney General


cc: Sean McCluskie, Chief Deputy Attorney General

Amanda Renteria, Chief, Division of Operations

Andrew J. Kraus III, Acting Director, Office of Program Oversight and Accountability



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Kern County Office of Education


August 11, 2017

California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, California 95814

Re: Kern County Superintendent of Schools Response to State Auditor's Report –

"Comprehensive School Safety Plans: School Districts, County Offices of Education, and

the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies"

Dear California State Auditor:

Attached please find our formal response to the California State Auditor's Report referenced above. We appreciate the opportunity to clarify our position on the issues raised in the report.

We also appreciate the recommendations made to help strengthen our safety plan implementation, and we look forward to working with our agency partners to improve upon our collaborative work to date.

Sincerely,

Mary C. Barlow
Kern County Superintendent of Schools

Enclosures





Kern County Superintendent of Schools Response to State Auditor's Report:
"Comprehensive School Safety Plans: School Districts, County Offices of Education,
and the State Must Do More to Ensure That School Safety Plans Help Protect
Students and Staff During Emergencies"

Introduction

The Office of the Kern County Superintendent of Schools (Kern) appreciates the opportunity to respond to the draft report of the State Auditor regarding comprehensive school safety plans. Kern was one of three county offices and three schools districts whose school safety plans were reviewed. We understand that our response will be included in your report when it is issued.

1

Safety of students and staff in all of Kern's instructional programs is our highest priority. We believe that we have considered and addressed the subject of safety, and the various elements required by law to be included in our safety plans. In addition, Kern has been active in addressing emergency preparedness and response, in coordination with multiple agencies, as discussed below. These efforts are not reflected in the draft report. We acknowledge that not all of our provisions related to safety are found within the plans themselves and we fully intend to incorporate elements found elsewhere by reference, and address any elements not fully addressed to date, as we revise and update our plans prior to the March 1 deadline.

2

Table 4 of the draft report is a graphical representation of your proposed findings on 20 elements in safety plans. You indicate that you examined two Kern plans for your review. For the record, those plans are for our court schools and our community schools. In many instances, you found that one plan satisfied an element and the other did not. We understand that the alleged non-compliance in those instances was with the court schools.

Court Schools

4
3

Court schools are programs where students are under the jurisdiction of the juvenile court and under the direct supervision of the probation department. By virtue of this supervision, and the design of court school facilities, these are the safest school campuses anywhere in the state. The Kern County probation department has its own safety plan for court school operations, which we have reviewed and comply with. This plan was shown to your office representatives.

3a

Many of the elements of student safety in court schools are under the control of probation officers and not within the county office's authority. We will address those later, but offer as an example the element of procedures for safe ingress and egress of pupils, parents and employees. Probation controls ingress and egress to court schools. Our office maintains a very positive working relationship with the Kern County Probation Department, with a rich history of collaboration on behalf of students.

Community Schools

The report also notes, in two places, that Kern has only one safety plan that covers all of its community schools. You contend that the law requires an individual plan for each community school site. We disagree.

5

As noted in footnote 2 to your report "Small school districts with 2,501 or fewer students may choose to meet this requirement [to adopt school safety plans] by developing a districtwide comprehensive school safety plan that is applicable to each school site." The authority for this statement is Education Code section 32228(d). Kern's community schools have never had a student population in excess of 2,500. Education Code section 1984 provides, in its entirety: "For the purposes of establishing and maintaining a county community school a county board of education shall be a school district." Since the legislature is satisfied that a small district need not have a separate plan for each site, there is no basis to conclude that a single plan for a similarly small county office community school program is prohibited.

6

Kern has a single safety plan for its community school operations. Nevertheless, we note that each of our individual community school sites has its own emergency plan adopted under the Standardized Emergency Management System (SEMS) and the National Incident Management System (NIMS).

8
7

The report says that Kern was not aware of its requirement to have school safety plans in the same manner as school districts. This is not correct. The existence of a comprehensive safety plan for its community schools is evidence that Kern was aware and, in almost all aspects, in full compliance with that requirement. As indicated below, a formal adoption of a plan for court schools, incorporating many safety elements already in place under existing Kern policies, will now take place. Kern had not been made aware of periodic advice and guidance from the California Department of Education on the subject of safety plans, due to miscommunication and changes in personnel assignments. Those problems have now been corrected both at Kern and at CDE.

Safety Plan Elements

Turning to Table 4:

Elements 1-5, Development and Submission

9
6a

Kern has a comprehensive school safety plan for its community schools, developed and approved by a school site council and presented to the county superintendent. This plan will be presented at a public meeting at the largest community school site prior to review by March 1. A formal plan for the juvenile court schools program will be developed, publicly presented and submitted to the county office for review by March 1. Thereafter, plans will be evaluated annually and amended where necessary.

Elements 6-13, School Climate and Environment

The report finds that all elements were met at the community school.

10

As for the court schools:

Elements 14-20, Disaster and Emergencies

Kern already has in place comprehensive office-wide policies and procedures for disaster emergency response. All community school students and staff participate in annual emergency preparedness drills. Where necessary, they will be adapted to meet the needs of students with disabilities as the plans are reviewed prior to March 1. Existing earthquake drop procedures will be modified to provide for drills once per quarter for elementary students and once per semester for secondary students.

11

Kern has office-wide agreements with the County of Kern and other public agencies dealing in a comprehensive manner with emergency responses. They specifically address the availability of sites for mass care and shelter. In addition, all Kern sites are civic centers available to the public which would make them accessible to the Red Cross and other agencies. The availability of court school sites is within the discretion of the probation department.

Active Shooter and Emergency Preparedness

Finally, a word about active shooter plans and emergency preparedness in general. Your report acknowledges that active shooter plans are not required by state law. However, in Kern we have focused on this issue as part of our multi-agency involvement called STAT: School Threat Assessment Task Force. This multi-agency team included the following organizations:

STAT was created to include key stakeholders at the table to identify best practices, provide reasonable and effective solutions and coordination of resources around the issue of threat assessment and emergency preparedness for schools, including our own court and community school programs.

STAT created guidance for agencies and schools, regular communication and updates and local training opportunities, and focused largely on active shooter trainings for Kern and district staffs.




Comments

California State Auditor's Comments on the Response From the Kern County Office of Education

To provide clarity and perspective, we are commenting on the response from the Kern County office. The numbers below correspond to the numbers we have placed in the margin of Kern County office's response.

1

We acknowledge the efforts that Kern county office has made related to school violence. Specifically, as detailed in Table 3, we note that Kern's safety plans contained optional procedures for responding to active shooter incidents. However, as depicted in Table 4, we also concluded that Kern's safety plans did not contain numerous other emergency preparedness procedures, including a program to ensure that pupils and certificated and classified staff were aware of and trained in earthquake procedures (element 19). Thus, Kern can do more to ensure that its schools have sufficient emergency preparedness and response plans in place.

2

The Kern county office is incorrect when it states that the non‑compliance was with the court schools. Specifically, as we note in Table 4, both the court school's and the community school's safety plans were missing multiple elements.

3
3a

As we noted previously, state law requires every county office that maintains a school to review and approve their schools' safety plans. This requirement includes court schools, community schools, and any other schools operated by the Kern county office.

4

We reviewed the court school's plan and found that it contained numerous deficiencies, which we note in Table 4. Thus, the Kern county office's review of this safety plan was not sufficient as it did not identify or correct the deficiencies we noted.

5

The exception to state law cited by the Kern county office does not exempt it from the requirement to have a separate plan for each school site. In enacting the requirement to adopt school safety plans, the Legislature specifically identified school districts and county offices, indicating that each has a discrete and specific duty to fulfill this requirement. Although the Legislature specified an exception to this requirement for small school districts, it specifically did not name county offices.

6
6a

As we state previously, county offices, like school districts, are responsible for ensuring that safety plans have the necessary procedures and policies to respond to an emergency and to foster a safe school environment, and that they develop and submit safety plans in compliance with state law. Because the Kern county office relies on one generic safety plan for all of its schools, rather than safety plans that are specific to each site, the Kern county office has no assurance that individual sites have individualized emergency procedures, such as up-to-date evacuation routes.

7

We are confused by the conflicting statements from the Kern county office concerning whether or not it was aware that state law required it to review and approve safety plans in the same manner as districts. As we state previously, staff at the Kern county office indicated that the county office had not included some required safety plan elements because it was not aware of them. Moreover, we asked the Kern county office to provide an alternate explanation for the missing elements, but it did not do so.

8

The safety plans we reviewed were not, in almost all aspects, in full compliance with state law. Table 4 shows that the safety plans were missing numerous required elements.

9

We note in Table 4 that the Kern county office did not demonstrate that its school site council wrote and developed the safety plans (element 1).

10

The Kern county office's responses indicate that it plans to only include certain elements that we identified as missing in its court schools' safety plans. However, as we stated previously, county offices are responsible for ensuring that safety plans adopted by these schools have the necessary procedures and policies to respond to an emergency and to foster a safe school environment. The requirement to review and approve safety plans extends to court schools, community schools, and any other schools operated by the Kern county office.

11

We are disappointed that the Kern county office did not share the office-wide agreements it references in its response. State law requires safety plans to include procedures to allow a public agency, including the American Red Cross, to use school buildings, grounds, and equipment for mass care and welfare shelters during an emergency for each school site. As we show in Table 4, our review of the Kern county office's safety plans did not contain any references to the office-wide agreements that the Kern county office refers to in its response (element 20).



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Placer County Office of Education


August 10, 2017

Via electronic mail and USPS

California State Auditor
Elaine M. Howle, CPA
621 Capital Mall, Suite 1200
Sacramento, CA 95814

Dear Ms. Howle:

I write in response to the California State Auditor's draft report entitled School Violence Prevention received by the Placer County Office of Education (PCOE) on August 7, 2017. First, I would like to thank you and your staff for your professional approach in conducting this audit and for the insight provided to PCOE as a result of your review of our school safety planning. It is my understanding that the auditors found PCOE staff to be cooperative during the audit as well as committed to the effort of creating a safe learning environment at all PCOE schools.

As I expressed to your auditors, I too, have a deep concern regarding the increased frequency of active shooter threats and incidents in California, as well as the rest of the nation. Sadly, as these incidents are on the increase, this audit report could not have been any timelier and I would like to offer my support for any effort to improve school safety planning across the state.

In the days immediately following the tragedy in Newtown, Connecticut, I directed county office staff to increase PCOE's crisis response preparation as a matter of critical importance. PCOE has significantly increased its response readiness through working with local law enforcement, providing professional development, conducting situational crisis drills, and equipping all county office facilities with emergency and communication supplies down to each of our classrooms. I am gratified to see some of the measures we have taken here at PCOE listed as best practice recommendations in the report. PCOE has taken a leadership role in assisting school districts in Placer County in safe school preparation by providing financial resources and professional development opportunities to school leadership.

PCOE recognizes the areas of improvement needed in its school safety planning as identified in the report. While we believe that some of the items of deficiency are already in place at PCOE, this office will take the necessary steps to further align its school safety practices with the administrative requirements of the California Education Code and will be prepared to implement any future changes in state law.

In response to the recommendations in the report, PCOE will:

1

I hope you find this response to be as intended, in a spirit of cooperation and expressing a commitment to move forward to improve the safety of our schools while meeting the school safety planning process and procedures required by state law.

Yours in education,

Gayle Garbolino-Mojica
Placer County Superintendent of Schools

cc: Phillip J. Williams, Deputy Superintendent, Educational Services
Martin Fregoso, Associate Superintendent, Business Services
Mary Ann Garcia, Chief Human Resources Officer
James L. Anderberg, Chief Operations Officer
Keith J. Bray, General Counsel




Comments

California State Auditor's Comments on the Response From the Placer County Office of Education

To provide clarity and perspective, we are commenting on the response from the Placer county office. The number below corresponds to the number we have placed in Placer county office's response.

1

Although the Placer county office did provide some school board policies that are available online, which we acknowledge previously, these policies did not address all the deficiencies we identified. For example, we could not find any evidence that the Placer county office had online school board policies related to notifying teachers regarding dangerous pupils and procedures for safe ingress and egress of pupils, parents, and employees. As we note in Table 4, none of the safety plans we reviewed contained these elements (elements 9 and 11).



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San Bernardino County Office of Education

August 11, 2017

Ms. Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Dear Ms. Howle:

Thank you for your interest in school violence prevention in California's K-12 public schools. As requested, this letter is a preliminary response to the California State Auditor's ("Auditor") draft audit report ("Report") "School Violence Prevention: School Districts, County Offices of Education, and the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies." We appreciate the opportunity to dialogue with your staff on this very important matter and to comment on the preliminary findings and recommendations in the draft Report. You will find below, the San Bernardino County Superintendent of Schools ("SBCSS") general comments and specific responses to the Report recommendations.

1

As the Report indicates, California's education institutions have a responsibility to create safe and secure learning environments (pg. 9). While schools have multiple measures in place to ensure the safety and well-being of students and staff, the occurrence of active shooter threats and incidents in schools nationwide has increased in frequency (pg. 10). Certainly, the readiness to prevent, identify and respond to all types of emergency incidents, including violence and active shooter threats on and around school campuses, should be a priority for all adults.

Auditor's Legislative Recommendations

To ensure that students and staff are prepared to respond to violent incidents on or near school sites, the Legislature should require that safety plans include procedures, such as lockdowns, recommended by federal and state agencies. The Legislature should also require schools to hold periodic drills on the procedures.

SBCSS Response

SBCSS is committed to serving the districts in San Bernardino County with guidance, support and best practices concerning the safety of school campuses. While current state law does not require schools to include procedures for responding to active shooter incidents in their school safety plans, SBCSS recognizes the importance and validity of this recommendation and would be supportive of proposed legislation in this regard. Additionally, SBCSS will continue numerous efforts in place to ensure the safety and security of school campuses, including:

Auditor's District and County Office Recommendations

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1st each year, county offices should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking systems and safety plan templates.

SBCSS Response

2
1b

SBCSS supports this recommendation and will review current policies and procedures, and implement improved procedures where necessary, to monitor and approve comprehensive school safety plans. The use of safety plan templates and document-tracking systems to monitor and approve annual school safety plans by March 1st of each year will ensure that schools have in place up-to-date safety plans that include all the requirements to comply with state law.

SBCSS believes it is important to note the requirements for comprehensive school safety plans put forth in Education Code ("EC") 32280-32288 in response to the Auditor's written comments on page 25 of the Report about site-specific safety plans. EC 32281 indicates that a "small school district" with fewer than 2,501 units of average daily attendance ("ADA") at the beginning of each fiscal year may develop a districtwide comprehensive school safety plan. The California Department of Education ("CDE") recognizes three separate schools operating under SBCSS. The three schools are: San Bernardino County Juvenile Detention and Assessment Center; Community School / Independent Alternative Education; and San Bernardino Special Education.

Juvenile Hall ADA during the 2016-17 school year had an ADA of 208.37. Community school / independent study had an ADA of 590.59. Most SBCSS special education classes are primarily housed on local school campuses. Those classes are covered under the local district / school safety plan. SBCSS has two stand-alone special education sites with a total ADA of 72.64 ADA. The total ADA for SBCSS for 2016-17 was 2098.00. Since 2013-14 school year, SBCSS district ADA has been below the 2,501 ADA level, which the CDE identifies as the demarcation between small school districts and others.

The district conducts school site council meetings regularly during the course of the school year, as well as holds biannual Local Control Accountability Plan("LCAP") forums. Attending these meetings are: school and district administration, teachers, paraeducators, students, parents, community members, and probation officers. School safety is discussed at school site council meetings and school climate is one of the state's eight required elements for district LCAPs. The district has allocated funds for probation officers housed at community schools to assist with safety concerns.

Specific actions SBCSS is committed to implementing, which pertain to the Auditor's recommendations for county offices of education include:

We appreciate the Auditor's attention to and concern for the safety of California's public school students. The safety and well-being of students and staff in California's public schools is of paramount importance. Students should be able to attend schools in safe and secure environments so that learning may flourish. We look forward to our continued efforts with the Auditor on this matter to see that all of our students have the ability to attend school in environment that are safe and secure in order to fulfill their greatest potential.

Sincerely,

Ted Alejandre
San Bernardino County Superintendent




Comments

California State Auditor's Comments on the Response From the San Bernardino County Office of Education

To provide clarity and perspective, we are commenting on the response from the San Bernardino county office. The numbers below correspond to the numbers we have placed in San Bernardino county office's response.

1
1a
1b
1c

During the publication process for the audit report, page numbers shifted. Therefore, the page numbers cited by the San Bernardino county office in its response may not correspond to the page numbers in the published audit report.

2

The exception to state law cited by the San Bernardino county office does not exempt it from the requirement to have a separate plan for each school site. In enacting the requirement to adopt school safety plans, the Legislature specifically identified school districts and county offices, indicating that each has a discrete and specific duty to fulfill this requirement. Although the Legislature specified an exception to this requirement for small school districts, it specifically did not name county offices.



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San Bernardino City Unified School District


August 11, 2017 Sent via Email and U.S. Mail:

California State Auditor
Attention: Elaine Howle, State Auditor
621 Capitol Mall, Suite 1200
Sacramento, California 95814

Dear Ms. Howle:

Thank you for your assistance in completing an audit of School Safety Plans within our District. The investigation by your team is most valuable in keeping our students as safe as possible, while assuring an appropriate learning environment.

I do have some observations for your consideration as we move forward in collaboration:

  1. While I agree that the School Safety Plans should include protocol for active shooter situations, there are other approaches which we have implemented to achieve the same result. Since the December 2, 2015 incident at the Inland Regional Center in San Bernardino, our District created new lockdown, lockout, and shelter procedures. This included handouts, posters and power point presentations throughout the District. We have conducted training for all school leaders on these new procedures. Moreover, many drills for schools were completed and public meetings conducted. Combined, over 500 substitute teachers and custodians received the same training. We implemented improved mass communication methods at all of our schools;
  2. The inclusion of safety procedures in School Safety Plans do not in and of themselves protect students. Rather, training, which our District has implemented, must be provided when confronting school violence. To this extent, I respectfully disagree with your conclusion that our oversight with respect to School Safety Plans has "put students and staff at risk". School Safety Plans are only one part of how we assure safe campuses with staff training being a far more important approach. Clearly, a School Safety Plan without training is ineffective. Training of staff, on the other hand, assures an appropriate response;
  3. Emphasis is warranted in preventing school violence before it occurs. Part of our staff training is aimed at recognizing circumstances that could lead to destructive events on or near our schools so that proactive measures can be taken before the devastation takes place;
  4. Your report makes reference to the fact that policies, training and other procedures were not included in School Safety Plans. I assure you, however, that policies do exist and safety training has been conducted within the District. I will make certain that our updated Safety Plans include this information;
  5. The SBCUSD has retained the services of an outside contractor to evaluate our campuses from the perspective of maintaining a secure learning environment. The project is ongoing presently and will take place over the next several months. We anticipate input from the retained contractor during the current school year. Our School Safety Plans are being updated at each of our campuses as mandated by the Education Code and we will be in compliance for the 2017-18 school year;
  6. Funding should be made available to the school districts to permit full compliance with School Safety Plan requirements.

Once again, I want to thank you and your members for the time and effort spent in our District towards the end of keeping staff and students as safe as possible. It is our mutual belief that establishing a culture of safety throughout the school community will promote student and staff security. Relationships among community, staff, parents, students and partners will create the desired result. We value your input and thank you for your assistance.

Very truly yours,

Dale Marsden, Ed.D., Superintendent
San Bernardino City Unified School District




Comments

California State Auditor's Comments on the Response From the San Bernardino City Unified School District

To provide clarity and perspective, we are commenting on the response from San Bernardino City Unified. The numbers below correspond to the numbers we have placed in San Bernardino City Unified's response.

1

We stand by our conclusion that the lack of oversight by districts and county offices of education may put students and staff at risk because they may not know how to properly respond to an emergency. Safety plans are a collection of procedures for schools to use in the event of an emergency, such as an earthquake, as well as policies to promote a safe learning environment. We note in Table 4 that San Bernardino City Unified is deficient in multiple areas. For example, nine of the 10 safety plans we reviewed were missing a discrimination and harassment policy (element 10). In addition, we assessed the supplemental evidence of training provided by San Bernardino City Unified and found that it did not include all of the information missing from the safety plans we reviewed.

2

Although San Bernardino City Unified does provide some school board policies online, which we acknowledge, these policies did not address all the deficiencies we identified. For example, we could not find any evidence that San Bernardino City Unified had online school board policies related to notifying teachers regarding dangerous pupils. As we note in Table 4, only one of the 10 safety plans we reviewed at San Bernardino City Unified contained this element (element 9). Further, we did not find evidence that the trainings conducted by district staff included all of the elements required in safety plans.




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