Report 2019-101 All Recommendation 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 for Legislative Action

To increase the transparency of LCAPs and ensure that stakeholders can provide an adequate level of oversight, the Legislature should amend state law to require districts and other local educational agencies to specify in their LCAPs the specific amounts of budgeted and estimated actual supplemental and concentration expenditures for each service that involves those funds.

Description of Legislative Action

As of January 2020, the Legislature has not taken action to address this specific recommendation.

  • Legislative Action Current As-of: January 2020

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To ensure that intended student groups receive the maximum benefit from supplemental and concentration funds, the Legislature should amend state law to require districts and other local educational agencies to identify any unspent supplemental and concentration funds annually by reconciling the estimated amounts of these funds included in their LCAPs with the actual amounts of these funds CDE reports having apportioned to them.

Description of Legislative Action

As of January 2020, the Legislature has not taken action to address this specific recommendation.

  • Legislative Action Current As-of: January 2020

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To ensure that intended student groups receive the maximum benefit from supplemental and concentration funds, the Legislature should amend state law to specify that unspent supplemental and concentration funds at year-end must retain their designation to increase and improve services for intended student groups and be spent in a following year. The Legislature should also require districts and other local educational agencies to identify in their LCAPs for the following year the total amounts of any unspent supplemental and concentration funds. In addition, it should direct the State Board to update the LCAP template to require districts and other local educational agencies to report in their LCAPs how they intend to use any previously unspent supplemental and concentration funds to provide services that benefit intended student groups.

Description of Legislative Action

As of January 2020, the Legislature has not taken action to address this specific recommendation.

  • Legislative Action Current As-of: January 2020

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To provide additional data for the State and other stakeholders and to align spending information with the dashboard indicators or other student outcomes, the Legislature should require CDE to update its accounting manual to direct districts and other local educational agencies to track and report to it the total amount of supplemental and concentration funds they received and spend each year.

Description of Legislative Action

As of January 2020, the Legislature has not taken action to address this specific recommendation.

  • Legislative Action Current As-of: January 2020

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To provide additional data for the State and other stakeholders and to align spending information with the dashboard indicators or other student outcomes, the Legislature should require CDE to develop and implement a tracking mechanism that districts and other local education agencies must use to report to it the types of services on which they spend their supplemental and concentration funds.

Description of Legislative Action

As of January 2020, the Legislature has not taken action to address this specific recommendation.

  • Legislative Action Current As-of: January 2020

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #6 To: Education, State Board of

To increase the transparency of LCAPs, by February 2020, the State Board should change the LCAP template to merge the Annual Update section with the Goals, Actions, and Services section.

60-Day Agency Response

Consistent with the October 17, 2019 response letter, the Board's January 2020 meeting agenda included an item recommending that the Board adopt a revised template that integrates the annual update and the LCAP consistent with this recommendation. The SBE approved this change on January 8, 2020.

  • Completion Date: January 2020
  • Response Date: January 2020

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

We reviewed the revised template and found that it incorporates the former annual update section in the "Goals and Actions" section. Specifically, LEAs will identify metrics and report baselines and outcomes for each of the three years of the template. This revision should reduce certain duplication that existed in the previous template and increase transparency.


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.

  • Estimated Completion Date: 1/8/2020
  • Response Date: January 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.


Recommendation #8 To: Education, State Board of

To ensure that districts and other local educational agencies produce clear and effective LCAPs and to reduce the likelihood of stakeholder complaints, by April 2020 the State Board should revise the instructions for the LCAP template to include, as best practices, key information from CDE's stakeholder complaint decisions about how districts and other local educational agencies can successfully demonstrate that they have principally directed districtwide spending for services toward intended student groups.

60-Day Agency Response

Consistent with the October 17, 2019 response letter, the Board's January 2020 meeting agenda included an item recommending that the Board adopt a revised template with instructions that incorporate the key information from CDE's UCP decisions on this topic. The SBE adopted the revised template on January 8, 2020.

  • Completion Date: January 2020
  • Response Date: January 2020

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

Our review of the revised LCAP template and instructions approved by the board found that they include key information from CDE's stakeholder complaint decisions we noted in our report.


Recommendation #9 To: Education, State Board of

To ensure that districts and other local educational agencies produce clear and effective LCAPs and to reduce the likelihood of stakeholder complaints, by April 2020 the State Board should revise the instructions for the LCAP template to instruct districts to ensure that their LCAPs are sufficiently clear and effective, including but not necessarily limited to ensuring that they articulate a logical connection between their needs and goals, that districts provide sufficiently detailed descriptions of services with the LCAP's Analysis subsection, and that LCAPs are written in a manner that is easily understandable.

60-Day Agency Response

Consistent with the October 17, 2019 response letter, the Board's January 2020 meeting agenda included an item recommending that the Board adopt a revised template with instructions that address this issue. Additionally, in order to strengthen the logical connection between goals, actions, and metrics included in LCAPs, the template includes a field in which LEAs must explain why each goal was developed and how the actions and metrics under each goal are related to achieving the goal. The SBE adopted the revised template on January 8, 2020.

  • Completion Date: January 2020
  • Response Date: January 2020

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

Our review of the revised LCAP template and instructions approved by the board found that they emphasize that districts should ensure their LCAPs include a logical connection between needs and goals, provide sufficiently detailed descriptions of services, and are written in language that is meaningful and accessible to stakeholders and the public.


All Recommendations in 2019-101

Agency responses received are posted verbatim.