In a letter on Monday, leaders of the state Senate and Assembly criticized proposed regulations on state funding for the state’s neediest students as inconsistent with the intent of the new school finance law.

Their letter to the State Board of Education, which must adopt the regulations in January, adds an exclamation point to similar criticisms from organizations representing low-income students, foster youth and English learners. Legislators and advocates are arguing that the proposed regulations for the Local Control Funding Formula or LCFF would give districts too much flexibility to decide how to spend money targeted for high-needs students.

Signing the letter were Senate President pro Tem Darrell Steinberg; Assembly Speaker John Pérez; Senate Budget Committee Chairman Mark Leno, D-San Francisco; Assembly Budget Committee Chairwoman Nancy Skinner, D-Berkeley; Senate Education Committee Chairwoman Carol Liu, D-Glendale; and Assembly Education Committee Chairwoman Joan Buchanan, D-Alamo.

The three-page letter suggests nine changes to the regulations and the proposed template for the Local Control and Accountability Plan or LCAP, which the State Board also is considering. Starting the next school year, every district and charter school will be required to adopt an LCAP, detailing how they will respond to  the eight priorities, including school climate, parent engagement and student achievement, that the Legislature mandated under the new school funding formula.

The regulations are an attempt to strike a balance between LCFF’s goals of giving school districts flexibility over spending decisions and ensuring that extra money allocated to high-needs students are spent on them. Legislators conclude those students need more protection. Among the recommendations:

  • Eliminate the option that districts could set goals and claim they raised student achievement for targeted students without actually spending proportionally more money on them;
  • Ensure that, in districts and schools with few high-needs students, money is spent directly on services for those students and not on school-wide or district-wide purposes;
  • Create a standard methodology for determining how much money for calculating how much districts receive under LCFF for high-needs students;
  • Standardize the reporting of outcomes and growth data under the LCAP so that districts statewide can be compared;
  • Make reporting of expenditures under the LCAP transparent so that parents and the public can see which services are for targeted students, how much will be spent on them and whether the expenditures are for schoolwide or districtwide purposes.

The legislators wrote that they appreciate “the scope and complexity of the task” facing the State Board. In what could be interpreted as an offer or help or a veiled threat if they weren’t satisfied with what the State Board adopts, they conclude, “If statutory changes are needed to realize the promise of the LCFF, we are prepared to make them.”

State Board Chairman Michael Kirst declined to comment on the letter other than to confirm in an email that the Board would be making changes to the proposed regulations. The Board sees the regulations and the LCAP “interacting together,” he wrote.

John Fensterwald covers education policy. Contact him or follow him on Twitter @jfenster. Sign up here for a no-cost online subscription to EdSource Today for reports from the largest education reporting team in California.


Filed under: Featured, Local Control Funding Formula, Reporting & Analysis

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  1. Eric Premack says:

    The legislators incorrectly assert that the “letter and intent” of the law requires spending more money on English learner and low-income students.

    In fact, the letter of the law merely requires districts to “increase or improve services” (not spend more) for the English learner and low-income students. While spending more money is one way to increase or improve services–it isn’t the only way and nothing in the law requires spending more.

    In addition to this rather substantial flexibility, the law also provides that the state board must allow districts to spend the funds at least as flexibly as the preexisting federal laws governing “schoolwide” programs. These federal laws allow schools to spend otherwise-restricted funds to benefit all students, not just the targeted English learner or low-income ones. If this flexibility wasn’t already huge, California’s law goes even further, extending this schoolwide flexibility to “districtwide.”

    The apparent intent of the law, as expressed through the title of the new funding formula and planning requirement–and all of discussion leading up to the law–is “local control.”

    For good or for ill, the new law is abundantly clear and explicit both in terms of intent (“local control”) and the letter of the law that calls for broad expenditure flexibility at a minimum.

    If these legislators had wanted what they demand in this letter, presumably they should have drafted the law in a fundamentally different fashion and titled the new formula and planning requirements with “state control” rather than “local control” verbiage.

    Can you say “buyer’s remorse?”

  2. Gary Ravani says:

    There are strategies that have proven successful working with disadvantaged populations, for example, those used by QEIA schools: reduce class sizes significantly, bring in specialists who can provide interventions for students and targeted, quality, professional development for teachers as well as site administrators. Also providing extra personnel for instruction in music and other arts, PE, and science which also provides time for regular teachers to collaborate and pays off in quality instruction in the regular classroom with the added benefit of a well rounded education for the students.

    That doesn’t mean that competitive salaries are not important also. There are districts who have had struggles with budget for years, and salaries have become non-competitive. As effort after failed effort to create bonus/merit pay schemes have demonstrated pay is not the primary motivational force for teachers. That being said, extreme discrepancies in pay between districts create situations where transfer to higher paying districts, higher pay for all district teachers that is, promote transfers, personnel “churn,” and disruptions to school staffs that undermine the ability of low pay districts to provide for their students.

    1. Jerry Heverly says:

      I’m still confused. The things you list aren’t targeted, are they? Professional development? How could we do that just to benefit the LCFF groups? Would specialists only teach in classrooms with poor and EL children? Would music and art programs be reserved for poor kids?

      1. Paul Muench says:

        I think Gary hit the nail on the head. This will come down to how much teachers are paid and where they work. There may be some teachers who will transfer to districts or schools with more poor and ESL students. Smaller class sizes for similar pay may help remove barriers to the desire to make this type of move. Within districts we may see changes in seniority rules so that higher paid teachers are required to work at schools with more poor and ESL students. Or pay rules may change so that teachers working at schools with more poor and ESL students are paid more. Whether this makes for better outcomes remains to be seen. There is some evidence that QEIA has produced good results, but we will see if there are any scaling issues with LCFF when all poorer districts compete for existing teachers. Gerald Grant in “Hope and Despair in the American City” claims that desegregation is required in addition to extra money. Professor Grant’s claim is that desegregation is the only approach to public education that scales. Although its not clear we have the distribution of incomes in CA to make this strategy work. We will see how this experiment of focusing only on more money/resources works out.

        And overall I would answer your last question, and similar ones, with yes. Poor kids will get more resources which means they could get art and music classes that richer english speakers do not get. This is just one way the details of the law could work out. I suppose Eric Premack is right that more money may not be spent as only more services is required. But it would be no surprise that more services requires more money. And clearly many people are already suspicious that more services could be meaningless if not backed by more money.

        1. Jerry Heverly says:

          Forgive my persistence but….you really think art classes for poor kids will be beneficial? I can’t believe that. It is tailor made for a stigma. “You’re one of those poor kids that gets the extra art class? Ugh!” And I can’t believe that financial rewards for teaching in poor districts is what everyone is talking about. All I”ve heard is how evil it would be to spend any LCFF money on salaries. I still don’t see anything here that I could advocate at an LCAP meeting. Everything so far seems geared for EL students (“art and music classes that richer english speakers do not get.”) How does my school spend LCFF money on poor kids and foster youth? Any specific suggestions?

          1. Paul Muench says:

            Jerry,

            I was just working with your example. It will be up to each district to decide how money is best spent. Perhaps some districts will choose music and art.

            1. Jerr Heverly says:

              I’m going to take the risk of giving offense here because I’m genuinely looking for ideas:
              1. I can’t believe you all dismiss the idea that there would be a stigma attached to any program for “poor, EL, and foster youth”. Right now no kid in my high school would ever say they were on free and reduced lunch because of this same reason. There is no way we would create an art class just for poor,EL, foster youth. If we did create such a thing no kid would voluntarily enroll.
              2. There is no way the district would try to spend the money to reduce class size. The politics of this would be explosive. And what classes would be reduced? Just for the three LCFF groups? See point one above.
              3. I haven’t heard (here or elsewhere) one realistic way we could spend LCFF money on the targeted groups.

              1. navigio says:

                Jerry, I am confused. We are already doing all this, with even more restrictions. How could we be doing that if it were impossible or even unrealistic?

              2. Paul Muench says:

                I have to second what Navigio said. Students at our school already have separate programs. I don’t know what students say to each other about the differential treatment, but many know about it.

                I expect there would be no voluntary enrollment just like school in general.

                I do agree that the results of LCFF could be explosive. I think the immediate concerns are smallish potatoes. The bigger issue is school desegregation that is waiting in the wings. My preference is more of everything for education, including integration. Not an easy decision to come to, but I think its better we all head in that direction before we end up in a bigger hole than we are now. Maybe we will see some LCFF money spent on magnet schools to encourage more integration. Of course, I’m an optimist.

          2. navigio says:

            we need to remember something: because a poor kid is getting art in school, it does not mean they are getting something that rich kids are not. The reality is that the disparity in resources transcends the school environment. this is a very real reason for LCFF, imho. the gov wants to push as much support for education to the family as politically possible because he knows those who have the means will fill in the gaps. in this sense, more ‘in-school’ resources for unduplicated students can clearly be justified even though it may result in disparities within districts.

            one other point: we are grouping this extra funding by district. those who have any significant ‘extra’ will be those with large majorities and/or concentrations of unduplicated students. this makes it much less likely that you will ever see poor kids in a school getting something that rich kids in the same school are not, simply because it is much less likely that you have any significant number of both in any one school (yes there are exceptions, but there are many, many, many schools with unduplicated counts over 95%. So disparate resources will mean between schools and not within them (mostly). We already have a lot of disparate resources between schools: rich ones have all the programs, poor ones do not (again, mostly).

            Intervention is a strategy that I have seen work wonders (yes, not only for EL students). We should not be concerned about a stigma that results from learning how to read, for example (in fact, even when these programs are selective, I have not seen stigmas result).

            QEIA already reduces average class size in those schools by about 30% compared to others in our district. That is a doable strategy. So is reducing class size district-wide (something LCFF tries to incentivize).

            If a district has unduplicated rates over 80% or so, it seems virtually any district wide strategy, be it program-based or employee incentive-based, should work to provide a benefit for those students.

            1. Jerry Heverly says:

              Navigio
              Could you list a couple things that we now do where money is only spent on poor kids? I read the state website on QEIA and it doesn’t look to me that this money has been only spent on these groups.
              High school kids have considerable freedom in choosing their classes. I doubt we could force a kid to take an art class if he or she didn’t want it.

              1. navigio says:

                Hi Jerry. You’re right that QEIA’s metrics are not explicitly low income or english learner, however, the criteria for that program are clearly a proxy for that (see extreme correlation between performance metrics and income level, parent education level, language status, etc). In the most recent QEIA report to the gov and leg, only 7% of students in those schools had a parent who graduated from college. Over 40% of the students did not have a parent who graduated high school. The average F&R participation rate was 84% and the average EL rate was 41%. In our district, the QEIA schools have 100% compensatory participation, and are 98% and 99% minority. Ours are an elementary and a middle school, and I expect high school demographics to look somewhat different on average.

                Much Title 1 and EIA money today is used on programs designed specifically to help low income and/or EL students. This can take many forms, but targeted intervention is a very common one I mentioned above. In the Title 1 case, a schoolwide program will often benefit some students that are not considered unduplicated, but the extent that this happens depends on the school demographics and the type of program. Title 1 is admittedly a bit fluid (see Manuel’s comments in that regard), but EIA restrictions are pretty tight, so I think looking at what those programs are funding today would be a good example of something specific that could be used for LCAP. I think this is corroborated by the fact that this year, before there are any specific rules regarding LCFF usage, districts appear to be simply treating things the same as last year, even providing ‘EIA’ allocations to school sites. My personal take is that when EIA money goes away (which LCFF does), then there will be extreme local site pressure to continue those programs in some form, otherwise it looks like money is being taken away from EL and low income students and just given to the district budget deficit. I think district leaders really need to be cognizant of that potential.

      2. Gary Ravani says:

        Jerry:

        Yes, QEIA funds were targeted. Those schools used their extra funding for reduced class sizes, typically lower than other district schools, and to bring in extra personnel, Reading Specialists for example, who provided specialized interventions for students and also worked with teachers to enhance general instruction.

        Obviously music and the arts, or other components of a well rounded education, should not be reserved for specific groups; however, it has been plain that it is the lower scoring schools, those eligible for QEIA funds, that typically suffered from the most demeaned curriculums, that is to say, curriculums most devoted to improving test scores in Math and ELA. QEIA allowed some schools to side-step that problem. Aside from the concentration on test score driven curriculums many/most other schools impacted by budget cuts tended to cut into programs away from the “core,” and that meant cuts to electives: music and the arts, etc.

        The range of problems in providing a well rounded education to students has been influenced by the confluence of CA’s general underfunding of schools, the budget crisis, and the decades long obsession with test driven “accountability.” It is not unfair to say these problems have been mitigated in wealthier districts over time.

        All of these issues are now complicated by LCFF/LCAP and how it is implemented. There are huge issues with bringing school personnel compensation back to pre-crisis levels as well as some COLA and the need for professional development for CCSS and SBAC. There is some extra funding for the latter, but it should be remembered that the best LCFF/LCAP can do is provide for a more just and equitable way to underfund education in CA as compared to the rest of the nation.

  3. Jerry Heverly says:

    Two questions:
    1. why are salary raises a “black hole”? You want to improve a district? Raise pay and attract the best candidates. I get it that–when it comes to money–everybody hates teachers and their unions but if you want higher test scores (I hope you don’t fall for this, but I bet you do) raise salaries.
    2. Suppose I’m one of the people writing the LCAP. I want to specify a few things I think the schools should spend the money on. Can someone give me six possibilities? It can’t be books (you want the poor kids in the room to have different books than the rich kids?); I can think of a million things it can’t be, but I have a hard time thinking of things it could be. I can think of ways to help EL students (classroom aides, for instance) but for poor and foster youth I ain’t got a clue. Can somebody enlighten me?

    1. karen swett says:

      Follow the CDE’s Guide for doing needs assessment. Look at the achievement data – longitudinal, trends – and do a Comprehensive Needs Assessment. This isn’t about what someone “thinks” is best. Follow best practice models once the need has been determined. And CERTAINLY – ask the teachers and the parents. They – not administrators – spend the most time with the kids. Ask them. A well-done needs assessment process will answer your questions….

      1. navigio says:

        In other words, follow through on the SPSA. Another facade of accountability.

  4. Karen Swett says:

    Spending IS transparent – all spending is described by a “code-string”. SACS coding provides the transparency. BUT LCFF does not have its own SACS RESOURCE codes. Yet. The CDE needs to provide a unique SACS RESOURCE CODE to each of the 3 types of spending: base, supplemental, concentration. Following the money is easy if you can read SACS reports and if each pot of money has it own name. Reading SACS reports is easy. That’s what we – Making Cents Work – does. We teach parents to read their schoolsite checkbook. We track/follow/ monitor ALL the money at a school site – not just Title I or EIA or QEIA, etc. Think about it – it’s our kids and our money. MCW can teach you how to do this.

    1. navigio says:

      Can you give me an example of one school’s checkbook? Pick one in lausd at random. I’d like to see the reports you refer to. I expect they are online and publicly accessible.

      That said, that we need an additional entity to provide resources (tools and education?) just to understand simple spending should make it clear that transparency does not exist to the extent it should. (Paul, I still owe you a response on this issue).

      1. Karen Swett says:

        I have hundreds of examples (all in Sac-City Unified). I send a request to the district budget office and they send me the report via email. The report is directly from our district fiscal software database. (We use Escape.) Making Cents Work is a grassroots effort – we started “teaching SACS” about 3 years ago. We are currently in the process of creating a website. We just created a FB page. We will be posting to both soon. What is the name of the fiscal software being used in LAUSD? Give me the name of the school site checkbook you would like to look at. I always look at demographic and achievement data before I request the site fiscal data. MCW’s tag line is: “Connecting Spending to Student Outcomes.”

        1. navigio says:

          I dont think its fair to expect community members and/or parents to need software in order to support transparency (assuming that was your implication–apologies if not).

          Regardless, why should someone have to ask for this in order to get it. One alternative would be to require districts to report school-level data to the state (just as they do with the district-wide SACS report). However, as an example, that state-level file is in access format, so you need that software (or some other similar) just even to read it. Then you need to understand databased manipulation to find your district. Of course there is no comparison over years, unless you want to import multiple years into a database and write SQL commands. Of course, you can go to ed-data and find some of this.. oh wait, they collapse multiple SACS codes into one.. etc. etc.

          The other is, of course, just to require them to publish it. Computer software is amazing in its ability to perform iterative operations in that way. ;-)

          Anyway, my goal of asking you about a school you’re not familiar with is that’s pretty much the situation 99% of the public is in; even if they are a parent at the school or district. So someone with essentially the most expertise at this should be able to get this info pretty easily. I am curious now as to how difficult this would be for you. LAUSD is admittedly better than some when it comes to budgets, so that might even be easier than most. I’d also be interested in whether its possible to get this for a charter school.

          Btw, don’t misunderstand my tone. I am honestly curious about this.

          1. karen swett says:

            Your tone is fine…. I hear comments like often. The fiscal data base is “live” and constantly changing. Our district has recently started posting SACS reports on its web site. In fact, they are flooding the web site. Unfortunately they are being selective as to the data they are querying and they are sorting data in a way that is mostly not useful. One must first learn to read the SACS code-string, then know how to ask for the report. After many years of doing this I’m very confident that my advice is good. Learn “how” to ask and you will get the total fiscal picture you need for the purpose you are working on. i taught myself how to use the Escape data base after I was given access to “help parents and schoolsite councils”. I had read-only access and pulled reports for parents, schools, board members, etc. You want to examine the cost of utilities, broken down by site? You want to teachers and substitutes as two different line items? You want to see how much was spent on “non-essential” books using LCCF money only? Then compare it to other money? Or you just want to follow the money at your school site. All this can be done and should be done. By the way – I’m a retired CA cert. teacher. My credential is K-12, Phys. Ed. It’s just a database. A very, very, very big and powerful database. Ask for “read-only” access to your district fiscal software, plunk yourself down in a parent resource center at your favorite school site, teach yourself how to navigate the software (If I can do it, you can do it) and follow YOUR money.

            1. Manuel says:

              Yeah, it is only a database. But one that can only be gotten into if you are running Windows XP. They can’t even get it to work in Windows 7. Windows 8? Nope. Mac OS? Hell, no. Linux? Double Hell, No. What is a non-Windows user to do? I think it is discrimination, that’s what I think.

              BTW, I have never ever heard of SACS in regards to LAUSD. But now I am curious…

              1. karen swett says:

                SACS – Standardized Account Code Structure. For “how to” check out the CSAM (California School Accounting Manual) at: http://www.cde.ca.gov/fg/ac/sa/ The CSAM is the bible of all education funding in CA. Then look at EC 41010.

                The fiscal database is internal to the district. Every district in the state uses some form of electronic bookkeeping. (Sac City Unified uses Escape software. I think it is great software – easy to understand and navigate.) All revenues and all expenditures are line items in the checkbook. It doesn’t matter if a district uses PCs or Macs. There is no discrimination…. if you want to follow the money you can.

  5. ACTs says:

    *CAROL Liu

    unacceptable error

    1. John Fensterwald says:

      Your are right; Sen. Liu’s first name was in error. My regrets.

  6. Doctor J says:

    Teachers and Administrators [with secret "me too" agreements with Boards to match teacher raises] are scurrying to feast on the “new money” just like a Cougar gobbles its fresh kill. The legislative letter is spot on — get the money to the students, not to the black hole of salary raises and benefit raises — especially to administrators who benefit from secret back room deals of “me too” when teachers get salary and benefit raises.
    Why are parents being denied participation in negotiation over the largest single line item for every one of the 1000 districts in California — salaries and benefits ? TRUE TRANSPARENCY must become the battle cry to get this money to our students and provide them with a 21st Century education.

    1. navigio says:

      True transparency has been the rally cry for maybe 15 years and clearly that’s not enough. It’s going to take determination by the legislature and state BoE to get any progress there. I am not holding my breath.