Report 2019-101 Recommendation 7 Responses

Report 2019-101: K-12 Local Control Funding: The State's Approach Has Not Ensured That Significant Funding Is Benefiting Students as Intended to Close Achievement Gaps (Release Date: November 2019)

Recommendation #7 To: Education, State Board of

To increase the transparency of LCAPs, by February 2020, the State Board should change the LCAP template to require districts and other local educational agencies to include analyses of the effectiveness of individual services, in addition to analyses of overarching goals.

60-Day Agency Response

The Board's January 2020 meeting agenda included an item recommending that the Board adopt a revised template. For the reasons explained in depth in the October 17, 2019 response letter, the proposed template does not require LEAs to evaluate the effectiveness of each individual action included in the LCAP. As noted, such an approach assumes a linear causal chain between each individual action and a particular student outcome, despite ample research and experience showing that multiple, individual actions often work together to support a broader goal to improve performance on a set of interrelated metrics. This recommendation would artificially force LEAs to view each action in isolation, which is more likely to undermine meaningful evaluation of programmatic effectiveness rather than enhance it. It would also lengthen LCAPs with potentially hundreds of lines of narrative that is likely to be repetitive and add little meaningful information, making it more difficult for stakeholders to use the LCAP as an engagement tool. Responsive to the underlying concern, the LCAP template instructions include language stating that, for purposes of assessing effectiveness of actions as part of the annual update, LEAs may group one or more actions with one or more metrics included in a goal. The instructions also encourage LEAs to do so if there are multiple, unrelated actions included under a single goal. The SBE approved the new LCAP template on January 8, 2020.

California State Auditor's Assessment of 60-Day Status: Resolved

We consider the recommendation resolved, although the State Board did not directly implement our recommendation. In its response, the State Board takes a narrow view of our recommendation. We recommend that it require districts to include analyses of effectiveness of individual services, in addition to analyses for overarching goals, so a broader perspective would not be lost. Our recommendation is consistent with state law, which requires the LCAP template to include an assessment of the effectiveness of specific services described in the LCAP toward achieving the goals. The analyses of individual services would allow districts to highlight the effectiveness of particular services. Without this kind of information, it can be difficult to determine, from among dozens of services provided, which particular services were effective in improving outcomes. However, by including language in the template instructions encouraging districts to assess the effectiveness of a single action/service if there are multiple unrelated actions under a single goal, the State Board's revisions are responsive to our underlying concern.

Additionally, the State Board's inclusion of the option for districts to develop "focus goals" that are more concentrated in scope to address areas of need with a more specific and data intensive approach will also help to clarify for stakeholders which services are effective by reducing the dozens of services for each goal.

All Recommendations in 2019-101

Agency responses received are posted verbatim.