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California State Auditor Logo COMMITMENT • INTEGRITY • LEADERSHIP

K–12 Local Control Funding
The State’s Approach Has Not Ensured That Significant Funding Is Benefiting Students
as Intended to Close Achievement Gaps

Report Number: 2019-101

Figure 1
CDE Calculates Target Supplemental and Concentration Funds for Districts Based on Their Populations of Intended Student Groups

Figure 1 is a graphic that describes the formulas for calculating base, supplemental, and concentration funds. A district’s base funding is determined by its students’ average daily attendance and grade level. As supplemental funds, a district receives an extra 20 percent of the base funding rate for its percentage of intended students. When the intended student groups exceed 55 percent of a district’s total enrollment, it receives as concentration funds an additional 50 percent of the base funding rate for its percentage of intended students above the 55 percent threshold. The figure also provides a hypothetical example calculation of these funds given a district of 100 students, of whom 75 are in intended student groups. The hypothetical base amount is $500 per student. The base funds calculation is 100 students multiplied by $500 equaling $50,000. The supplemental funds calculation is $50,000 base funds multiplied by 20 percent multiplied by 75 percent equaling $7,500. The concentration funds calculation is $50,000 base funds multiplied by 50 percent, multiplied by 20 percent (or 75 percent minus 55 percent) equaling $5,000. Total LCFF funding is $50,000 plus $7,500 plus $5,000 equaling $62,500 total LCFF funding.

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Figure 2
Because of Differences in Their Student Populations, Our Selected Districts Received Varying Amounts of LCFF Funding for Fiscal Year 2018–19

Figure 2, a graphic presenting for the three selected districts their fiscal year 2018-19 intended student group populations, average daily attendance, and amounts of base, supplemental, and concentration funds. 44 percent of students enrolled in Clovis Unified were in the intended student groups. Clovis Unified had average daily attendance of 41,460. Clovis Unified received $342.6 million in base funds, $29.9 million in supplemental funds, and no concentration funds, for a total of $372.5 million in LCFF funding. 77 percent of students enrolled in Oakland Unified were in the intended student groups. Oakland Unified had average daily attendance of 34,270. Oakland Unified received $284.8 million in base funds, $43.7 million in supplemental funds, and $31 million in concentration funds, for a total of $359.5 million in LCFF funding. 62 percent of students enrolled in San Diego Unified were in the intended student groups. San Diego Unified had average daily attendance of 98,760. San Diego Unified received $821.1 million in base funds, $101 million in supplemental funds, and $26.8 million in concentration funds, for a total of $948.9 million in LCFF funding. We note that total LCFF does not include add-on funding districts received through the Targeted Instructional Improvement Block Grant program, the Home-to-School Transportation program, and the Small School District Transportation program.

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Figure 3
LCFF Relies on Local Decision Making and Oversight

Figure 3, a chart describing the state and local entities involved in overseeing and making decisions related to LCFF funding. At the state level, the State Board is California’s K-12 policy making body that adopts regulations and the LCAP template. CDE collects and reports certain data from county offices and districts, manages the dashboard, provides guidance to county offices and districts, and issues reports as part of the uniform complaint process. At the local level, 58 county offices approve districts’ LCAPs and ensure that the LCAPs adhere to spending requirements for supplemental and concentration funds. CCSESA developed an LCAP approval manual, which county offices can use as guidance when approving LCAPs. Approximately 1,000 districts decide how to spend supplemental and concentration funds and explain their decisions in their LCAPs. Approximately 10,000 school sites receive and spend some of the districts’ supplemental and concentration funds. Districts must consult with stakeholders, including parents and teachers, in developing their LCAPs. They must hold public meetings to solicit recommendations from members of the public regarding the services and expenditures in their LCAPs. County offices and stakeholders are key oversight entities for districts’ spending of supplemental and concentration funds.

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Figure 4
LCAP Development and Approval Is an Ongoing Process

Figure 4, a chart showing the timeframes and key milestones for the State, districts, and county offices in the LCAP development and approval process. In October, districts begin developing their LCAPs for the upcoming school year and engage stakeholders to gather input and feedback for the LCAP. Beginning in November, county offices conduct LCAP trainings for districts. Usually in December CDE releases the California School Dashboard. County offices conduct preliminary review of districts’ LCAPs in April through June. July 1 is the final day that districts may submit their LCAPs to the county. District’ work with their county office to address concerns related to their LCAP after submitting it. County offices then conduct formal LCAP reviews. October 8 is the final day that county offices may approve LCAPs. Though LCAP approval is required by October 8, the recommended approval date is September 15 to coincide with budget approval timelines. If a district’s LCAP is not approved by September 15, a conditional budget approval may be an option, where appropriate. County office and local stakeholders, such as parents, are the main safeguards that exist to ensure that districts develop clear and informative LCAPs. Thus, the quality of the county offices’ review and the quality of stakeholder engagement can have a significant impact on the LCAPs.

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Figure 5
Differentiated Assistance Is the State’s Primary Process for Addressing Achievement Gaps

Figure 5, a chart describing the three levels of California’s System of Support. Level 1 is voluntary technical assistance. State and local agencies provide support resources and tools that districts may use to improve student performance. Level 2 is differentiated assistance. County offices provide individually designed assistance for districts to address performance issues, including achievement gaps among intended student groups. CDE provides differentiated assistance for county-run schools such as juvenile court schools. Level 3 is intensive intervention. The state superintendent of public instruction may require further interventions for districts with persistent performance issues that do not improve over a specified time period. CDE implemented this level in 2019. The chart provides additional detail for differentiated assistance. Specifically, it shows that CDE releases the dashboard in December. County offices identify which districts have achievement gaps that require differentiated assistance. A county office must offer differentiated assistance to a district if any student group has dashboard indicators at red or not met for two or more LCFF priorities. County offices work with these districts to review dashboard and other local data to determine strengths and weaknesses and to identify how and why subgroups are underperforming. With guidance from county offices, districts identify effective, evidence-based programs and practices that will address their areas of weakness. Toward the end of the school year county offices send districts a final letter summarizing the identified programs and practices. The following summer and following school year districts incorporate into their LCAPs programs and practices they identified with their county offices.

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Figure 6
Regulations Led to Different Proportions of Base, Supplemental, and Concentration Funds Than Full Implementation of State Law Would Have Provided

Figure 6, a chart depicting three hypothetical first year funding examples. The first bar chart shows the target LCFF amount, which is based on state law related to intended student groups. The hypothetical total is $200 million of which the base funds are 80 percent, or $160 million, and the supplemental and concentration funds are 20 percent, or $40 million. The second bar chart shows the transition LCFF amount that would result from applying the same proportions of base, supplemental, and concentration funds that exist in the target LCFF amount. The total hypothetical transition amount is $140 million, of which 80 percent, or $112 million, would be base and 20 percent, or $28 million, would be supplemental and concentration. In comparison, the third bar chart shows that following the regulations adopted by the State Board, which are based on prior year’s spending, led to different proportions of base, supplemental and concentration. Specifically, 95 percent, or $133 million, of the $140 million hypothetical transition amount was base and 5 percent, or $7 million, was supplemental and concentration.

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Figure 7
State Regulations Resulted in Less Supplemental and Concentration Funds for the Three Selected Districts

Figure 7, a chart depicting a $320.6 million dollar difference in funds the three districts we reviewed identified as supplemental and concentration from fiscal year 2013-14 through 2018-19 that resulted from following state regulations compared to basing supplemental and concentration funds on the funding formulas in state law. The chart shows that if the three districts had based their supplemental and concentration funds on funding formulas in state law they would have identified $170.3 million in fiscal year 2013-14, however by following the regulations they identified $33.1 million as supplemental and concentration funds. Over the following years the differences slowly decreased. In fiscal year 2014-15 the funding formula approach would have identified $193 million as supplemental and concentration, the regulations’ approach identified $78 million. In 2015-16, $218 million compared to $165.6 million. In fiscal year 2016-17 $224.9 million compared to $211.3 million. In fiscal year 2017-18, $227.2 million compared to $222.5 million. Finally, in fiscal year 2018-19, the regulations approach actually resulted in more supplemental and concentration funds than the funding formula approach: $234.7 million compared to $232.5 million. We note that for fiscal years 2013-14 and 2014-15 when a district did not report the amount of supplemental and concentration funds it budgeted in its LCAP, we used the amount of expenditures it reported.

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Figure 8
LCAPs Consist of Five Main Sections, Two of Which Contain Duplicative Information

Figure 8, a color-coded graphic presenting the five main sections of the LCAP and the subsections of each main section. The subsections that are included in multiple main sections are highlighted a specific color. In the Summary main section there are seven subsections: the story, highlights, review of performance, greatest progress, greatest needs, performance gaps, and budget summary; all of which are grey because they are not duplicated. We note that the budget summary no longer exists in the version of the LCAP template that CDE presented in January 2019. The Annual Update main section includes subsections of goals, state and/or local priorities, expected annual measurable outcomes, actual annual measurable outcomes, planned actions/services, actual actions/services, budgeted expenditures, estimated actual expenditures, and analysis. The analysis subsection includes analysis of overall implementation, overall effectiveness, material differences, and changes made to the LCAP as a result of this analysis. The Stakeholder engagement main section has two subsections: first, the involvement process subsection, which describes how, when, and with whom the district consulted as a part of the planning process for the LCAP; and second, the effect on the LCAP subsection, which describes how these consultations affect the LCAP for the upcoming year. The goals, actions, and services main section includes the following subsections: goals, state and/or local priorities, expected annual measurable outcomes, identified needs, planned actions/services, and budgeted expenditures, estimated actual expenditures. All of these subsections except identified needs are color coded to indicate they are duplicated in the annual update section. The final main section is demonstration of increased or improved services for intended student groups. It includes three sub sections: estimated supplemental and concentration grant funds, percentage by which to increase or improve and a description of how services provided for intended student groups are increased or improved by at least the percentage identified, either quantitatively or qualitatively, as compared to services provided for all students in the LCAP years, and identify each service being funded and provided on a schoolwide or districtwide basis. None of these subsections are duplicated.

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Figure 9
By Collecting and Reporting Districts’ Spending Information, the State Could Strengthen the Links Between Spending and Outcomes

Figure 9, a graphic that describes the information currently provided in district LCAPs and accounting systems as well as the dashboard indicators. The graphics explains that districts currently present certain supplemental and concentration spending information in the LCAP; for example, Service 1: provide teacher collaboration time to help inform instruction. Amount; $4 million. Service 2: provide an intervention and credit recovery program to improve graduation rates. Amount: $225,000. The districts accounting system currently presents the following information: Service 1 budget reference: certificated personnel salaries and benefits. Service 2 budget reference: services and other operating expenses. The dashboard includes indicators for mathematics, English language arts, graduation rate, college/career, English learner progress, suspension rate, and chronic absenteeism. The graphic indicates a disconnect between the LCAPs and accounting systems because currently districts do not consistently track all of their supplemental and concentration funds in their accounting systems, and the State does not require districts to report those expenditures in a way that aligns with dashboard indicators. The graphic indicates there is a disconnect between the accounting systems and the dashboard because spending is not aligned with outcomes there is no meaningful link between spending and outcomes. Finally, the graphic indicates that the State needs to develop a method for collecting spending information that would allow it to link spending and outcomes.

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Figure 10
By Implementing Our Key Legislative Recommendations, the State Could Better Ensure That Supplemental and Concentration Funds Benefit Intended Student Groups

Figure 10, a chart describing the current concerns we identified regarding supplemental and concentration funds, LCAPs, and intended student group outcomes. The current concern for related to supplemental and concentration funding is that State law does not require districts to spend their supplemental and concentration funds to benefit intended student groups nor does it require that they track their spending of these funds. Our recommendation is that the Legislature amend state law to require that districts annually reconcile the amounts of supplemental and concentration funds in their LCAPs with the actual amounts CDE reports having apportioned to them, and specify that unspent supplemental and concentration funds at year-end maintain their designations and carryover to a following year. The intended result is better controls to ensure that districts actually spend the supplemental and concentration funds they receive to benefit intended student groups. The chart also describes our concern that LCAPs do not consistently provide transparency for stakeholders or clearly communicate how effectively districts meet their students’ needs. We recommend that the Legislature amend state law to require the districts specify in their LCAPs the specific amounts of supplemental and concentration funds they plan to spend for each service that involves those funds. The State Board should require districts to include in their LCAPs’ analyses of the effectiveness of individual services. The intended result is better transparency through LCAPs’ inclusion of specific amounts and analyses of supplemental and concentration funds that districts plan to use to provide services for students. The last concern we identified was that policymakers and other stakeholders lack adequate information to assess the impact of supplemental and concentration funds on the educational outcomes of intended students groups and closing achievement gaps. We recommend that the Legislature require CDE to develop and implement a tracking mechanism that districts and other local educational agencies must use to report to it the types of services on which they spend their supplemental and concentration funds. As a result, stakeholders will have better access to uniform data statewide about the services supplemental and concentration funds support, and data that could enable stakeholders to begin determining the effectiveness of those funds in closing achievement gaps.

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