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County offices to cut districts some slack for now on their LCAPs


Parents made suggestions in the form of post-it notes at an LCAP forum in San Diego Unified. Credit: Karla Scoon Reid, EdSource.

Parents made suggestions in the form of post-it notes at an LCAP forum in San Diego Unified. Credit: Karla Scoon Reid, EdSource.

State and county education officials are seeking to reassure school districts that might be worried that county superintendents will reject the new accountability plans they’ll submit by July 1 for the 2014-15 year. Tighter scrutiny will come, just not for the initial plan.

“The approval process is fairly objective, at least this year” and should be non-judgmental, Christine Swenson, director of the state Department of Education’s Improvement and Accountability Division, told the State Board of Education last month.

School district officials are in the process of putting together their first Local Control and Accountability Plans (LCAPs), which are required under the state’s new financing system. (County offices of education provide services for special-needs students, students in juvenile detention and students in alternative schools. Their LCAPs for those students will need approval from the Department of Education.)

Peter Birdsall, executive director of the California County Superintendents Educational Services Association, backed up Swenson’s perspective.

“There is the expectation of a good-faith effort (by school districts),” he said. “This is the first year, so nobody should have a budget denied for lack of legal compliance.”

He said he expects the “overwhelming majority” of districts will have their LCAPs and budgets approved by Aug. 15, with perhaps a few given a conditional approval.

All school boards must pass an LCAP by July 1 detailing how they will spend dollars from the Local Control Funding Formula over the next three years. The LCAP must respond to eight academic and school-climate priorities that the Legislature listed in the new finance law. The LCAP should list measurable goals, backed by data.

Examples might be lowering the dropout rate by X percent or raising the reclassification rate of English learners by Y percent. The plan should specify how the district will achieve those objectives for all students as well as for low-income students, foster youths and English learners, who will get extra money under the formula. One section of the LCAP asks districts to describe what they did to solicit views of parents, students and others from the community and if or how they incorporated those suggestions.

The LCAP is intended to hold the district accountable for making progress. County superintendents, who must approve districts’ LCAPs, will determine if districts must take action to improve and whether to impose stronger sanctions if they are chronically failing to meet goals. But not this year, Swenson, Birdsall and others agreed.

The State Board is still 18 months away from adopting an evaluation rubric, which will provide the criteria for determining whether a district’s LCAP passes muster. And the California Collaborative for Educational Excellence, the new agency that the funding law established to work with districts on areas of weakness, has yet to get going despite a $10 million appropriation to launch it. Gov. Jerry Brown and the Legislature have yet to name appointees to the governing board.

Limited oversight this year

For the initial LCAP, Swenson defined the county offices’ circumscribed role as verifying whether a district has met three criteria under the regulations that the State Board of Education adopted in January:

  • Did the district adhere to the LCAP template, filling out all of the sections covering parent engagement, goals and actions?
  • Does the district have sufficient revenue to meet the commitments it made in the plan?
  • Does the LCAP meet the law’s “proportionality requirements” – laying out how the district will improve or expand services and programs for low-income children, foster youths and English learners proportional to the extra dollars that these students bring to the district?

Districts’ responses will vary. Some will set ambitious goals, others minimal. Some will concentrate new resources on a few priorities, such as hiring counselors or creating after-school or career-oriented programs. Others may allot bits of money for many purposes.

It’s not the county’s role this time to determine whether the district has chosen the right goals and the smartest use of resources, said Anne Campbell, San Mateo County superintendent of schools.

“As long as districts have done stakeholder engagement, addressed the eight state priorities, set reasonable goals and allocated resources, that’s what’s required this year,” she said. “When we get to next year and have some data to show on achieving goals, then we can say, ‘Are you making progress to your goals?’”

Campbell said that she’s also aware of “the really compressed timeline” facing districts. While some districts – Redwood City School District in particular – started holding parent and community meetings last fall, others waited until the State Board adopted regulations in January to start the LCAP process.

Rather than wait for districts to submit their LCAPs in June, Campbell said that the San Mateo County office has been in contact with the 23 districts in its jurisdiction. Her office has paired an administrator who works in school finance with one who works in programs and instruction – two divisions that in the past had little collaboration. As a team, they have met with superintendents and board members, she said, and they will review individual districts’ draft LCAPs well before they are submitted for approval.

“If districts have not been out to engage stakeholders, we will give suggestions,” Campbell said.

Birdsall said other county superintendents have been proactive as well. “We want an approved template, so we hope that when the LCAP arrives, there are no surprises,” he said. The counties will use a standard of “reasonableness,” he said. “If you are saying you have a counseling program for 8th and 9th grades for students performing below grade level, how many counselors will you need? We will ask where are resources?”

Quest for consistency

County oversight is nothing new for school districts. Since 1991, county offices have monitored districts’ budgets and finances to verify that they can meet their short- and long-term obligations. With the settlement of the Williams v. California lawsuit in 2000, county offices began monitoring low-performing districts’ facilities and student access to qualified teachers and textbooks.

Overseeing programmatic and academic goals is new, however, and those districts that have had tensions with county superintendents over budgets may be feeling nervous about the LCAP oversight, said Wes Smith, executive director of the Association of California School Administrators.

He and Birdsall have met several times to discuss consistent standards for approving LCAPs. With 58 counties, there should not be 58 different expectations, Smith said. Birdsall said that his organization will release LCAP guidelines for county superintendents by the end of April.

Campbell said that her impression is that districts are working hard and taking the LCAP seriously.

But in testimony last month before the State Board, several civil rights advocates cited issues of concern. The quality of parent engagement among districts has varied substantially, students’ concerns weren’t being heard, and districts weren’t making enough achievement data available, they said.

Smith agreed that districts should be doing these things, but said they should not be punished for it if they aren’t up to speed this year. Next year, he said, they should have a plan reflecting those commitments and “be held accountable for engaging the community in meaningful ways.”

John Fensterwald covers education policy. Contact him and 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.

You can follow other EdSource articles on how selected districts are implementing their  Local Control and Accountability Plans through the Following the School Funding Formula project.

 

Filed under: LCFF Tracker, Local Control Funding Formula, Parent Involvement

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25 Responses to “County offices to cut districts some slack for now on their LCAPs”

  1. Manuel said

    on April 22, 2014 at 12:56 pm

    LAUSD’s LCAP is still being worked on, but it is almost done if one is to believe what Superintendent Deasy presented to the Board on April 8.

    However, if the LA County Office of Education is paying any attention, the proposed budget for the Supplemental and Concentration grants that accompanies this LCAP does not pass the “proportionality requirement.”

    A quick scan of this budget shows that nearly $10 million will be spent on foster students which number 11,604, while $21.72 million will be spent on 154,110 English learners. And that includes $10.83 million that will go to the “Language Acquisition Branch.” Is this proportionality? Not to this layman.

    But it gets better: $57.46 million will be spent on 6,801 students currently enrolled in LAUSD’s Options programs because, as the Superintendent put it, “one size does not fit all.” What is interesting is that the Options program is the Continuation, Opportunity, and Community Day Schools. Students going there can’t function in “regular” schools. Given that this translates into $8,449/student, it seems that a decision has been made that these schools will be funded entirely by the Supplemental and Concentration grants. Is this proportionality? Is this even legal?

    The budget also shows that nearly half the funds will be spent on meeting the needs of Special Education students. Yes, I know that neither the state nor the feds fund Special Ed well (LAUSD got 30 cents on the dollar according to their 2013-14 budget). But is this a good enough reason for taking half of the “extra” grants? It doesn’t seem very proportional to this layman.

    I do hope that LACOE will pay attention not just to the verbiage in LAUSD’s LCAP but to the numbers that are in there.

    If they don’t, well, there oughta be a law…

  2. Don said

    on April 22, 2014 at 8:28 am

    Let’s use a real world example to illustrate the problem with the LCAP at present. Not long ago my children attended an elementary school with 60% Chinese population. The majority of students entering kindergarten were English Language Learners. The school received its targeted allocation of EIA-LEP funding, about $60K, but it never used the funding to address the English needs of the students and instead folded it into the general budget. Though I repeatedly complained about this misuse of Tier III funds, the district did nothing to remedy the problem. Why? Central offices are far removed from what schools do and for this reason the goals of a district LCAP will not easily translate to school sites. District offices don’t run schools. They run bureaucracies. It is very rare to see downtown supervisors at school sites in San Francisco. And SFUSD is about 8% of the size of LAUSD where the bureaucracy must be much farther removed. Even if you complain about a specific misuse of funds it is hard to get any action. Only a concerted effort by the Chinese parents would have made an impact and that is a group that rarely applies political pressure. I have little faith that SFUSD will have ANY control over the implementation of its LCAP at school sites. That’s why school site LCAPS are a better idea.

    In regard to the rollout of the LCAP in this district, the district has held two community meetings so far. According to the literature on the district timeline for community engagement, SFUSD doesn’t plan to release a draft LCAP until a May 22 BOE meeting, after the 4 community meetings are held. The PAC will provide recommendations to the draft 5 days later. Do you see the problem here? The public has no opportunity to respond to the draft itself during the community engagement process. All the meetings were held prior to the release of the draft. The only real opportunity for feedback on the draft itself is at public comment when the Board votes on the LCAP a month later.

    • navigio replied

      on April 22, 2014 at 1:14 pm

      I dont think EIA/LEP was tier 3 so it shouldn’t have fallen under the tier 3 flexibility schools got (?). Eia has some of the most restrictive use possible and I’m pretty sure folding it into the gf would be illegal.

      • Don replied

        on April 22, 2014 at 2:12 pm

        I can assure you that LEP is Tier III and that it was only one of 2 or 3 programs out of 42 that were not flexed in ’09, SPED being one of the others and, I believe, TIIBG. That it was a clear violation of law was of little concern to either SFUSD or the CDE when I raised these issues. Individuals have entirely lost their ability to get redress from the CDE, after all, LCFF is an effort to push accountability down to the districts. Christine Swanson, mentioned in the article, has just been named director of the LCFF division numbering four employees. We are on our own because the Collaborative for Educational Excellence doesn’t have a mandate to enforce code either.

        Re: Manuel’s comment at 12:56, one can take away the idea that a draft LCAP has provided some information to help the public in its efforts at oversight, even if it may be hamstrung to effect change. SFUSD has provided nothing substantive, no draft, no numbers, nothing.

        Oversight by disparate and often uninformed parent individuals and groups is likely to have little influence on the LCAP. Many members have no idea about the processes of oversight. The PACs and DELAC in this town are filled by Board appointees who don’t make waves. They will not ask hard questions such as why SFUSD is not using its weighted student formula site-based budgeting process to allocate LCFF grants? Without an explanation from the district to the contrary, I assume they withheld this funding to keep control of it from the central office for the purpose of providing disproportional funding to select schools.

        • navigio replied

          on April 22, 2014 at 9:17 pm

          Thanks don, I stand corrected. I think what happened is our district chose not to flex eia so when they presented the tier iii list eia was not on it. Mea culpa.

          • Don replied

            on April 23, 2014 at 9:48 am

            Navigio, EIA-LEP was excepted from the flexibility legislation SB X3_4,2009 so they couldn’t have flexed it if they wanted to. On the other hand, districts like SFUSD simply ignored the law anyway and got away with it because THEY KNOW that the CDE will do nothing to compel compliance. I think you can count on one hand the number of times the CDE ever held back an apportionment for failure to comply with Ed Code and there have been some egregious stuff, not just minor skirting of the law. But the legislature excepted LEP for good reason in 2009 and even then the CDE and its Uniform Complaint Procedures Division did nothing. That legislation like LCAP is just there for window dressing. Around 2009 much of the state monitoring was canceled and I suspect that there won’t be much on the ground monitoring going forward. If that was replaced by a robust community review process with clear repercussions, the loss of state monitoring might be reasonable. But the whole philosophical thrust of LCFF from a compliance perspective is one of collaboration not punishment. To make that’s a quaint idea – laws without enforcement. Why bother?

          • Don replied

            on April 23, 2014 at 9:55 am

            Meant to say *** to me that’s a quaint notion***

            So if you don’t signal a lane change you get a big fine, but if a school district fails to provide specific instruction to thousands of students with targeted funding intended for that purpose, it gets a pass and a commendation like SFUSD.

          • navigio replied

            on April 23, 2014 at 11:07 am

            Ok, so I was right but for the wrong reason. ;-)

            Anyway, it’s surprising. Seems the SSC members could be held liable (chair has to sign the plan that does this) as well as the board (who has to approve that use).

          • Paul replied

            on April 23, 2014 at 10:02 pm

            Your point about relaxation of state-level (also county office-level) monitoring requirements during the years of funding “flexibility” is very important. LCF seems to make the vacuum permanent. Much will depend on how earnest a district is, and how concerned its voters are.

      • Manuel replied

        on April 22, 2014 at 2:13 pm

        navigio, it is illegal only if they get caught.

        BTW, EIA funds are no more under LCFF. That’s probably why LAUSD was confident that it would not get in trouble when it transferred the funds originally labeled EIA and under the oversight of the ELACs into something else but now controlled solely by principals.

        What I am curious is why aren’t similar “constrains” put on the expenditure of the S & C grants. A once-a-year look-over of the LCAP by a district-wide ELAC will be enough? That makes no sense. But then again, nobody ever said that politics make sense.

        • Don replied

          on April 22, 2014 at 4:16 pm

          RE: Tier III

          From Long Beach USD or you can check out the CDE explanation of EIA folded into LCFF here: http://www.cde.ca.gov/fg/aa/lc/lcfffaq.asp

          Local Control Funding Formula
          March 11, 2014

          What is LCFF?

          LCFF replaces revenue limits and over 40 state categorical programs, including K-3 CSR, Tier III and Economic Impact Aid

          LCFF includes a Base Grant, Adjustments, and Supplements

          Per student base amount

          Grade level adjustments

          Supplemental and Concentration Grants (demographics)

          LCFF is designed to improve student outcomes

          Local flexibility to meet student needs

          Simplicity to aid transparency

          Equity through student-focused formula

          Performance through aligned program and budget plans

          Manuel, not to lost track of the real issue – the LCAP is not a transparent process that will create collaboration between stakeholders, with the possible exception of some small districts. The notion that two relatively ineffectual parent advisory committees will successfully spearhead this process is indulgent optimism.

        • navigio replied

          on April 22, 2014 at 10:56 pm

          its not my answer, but the answer will be that ‘local control’ means no constraints. the state has backpedaled a bit on that, but its still more that way than it used to be.

          btw, i have a new theory about lcff. im noticing people are so focused on S&C grants that they’re completely forgetting to notice where all the base funding is going. dorothy, are we in troy?

  3. Tressy Capps said

    on April 22, 2014 at 6:53 am

    Set standards. If they are too hard to follow, change the rules. Sounds like a government program. Set the bar high and keep it high. America’s future depends on it.

  4. Paul said

    on April 21, 2014 at 11:26 pm

    Well said, navigio and Claire!

    I would add that these plans and structures can be used for good or ill, i.e., that they can be taken seriously or glossed over. Vague, outdated documents and moribund advisory committees usually signal a negligent administration, an authoritarian leader, or high turnover.

    When I used to go to interviews for teaching positions, I always tried to dig up SPSAs. Teachers on the panels had never read them, and administrators were invariably surprised that a newcomer would bother. If I sensed that these were not people I wanted to work with, I would have fun asking incisive questions. “How comfortable are you with a grading policy that allows virtually all of your students to pass algebra, when the CST says that only 6% are proficient?” “Your report highlights math achievement as a problem. What kinds of intiatives do you have in mind for addressing the problem?”

    Whether during the first year of LCF or in the future, county offices of education cannot be expected to provide a meaningful review of the LCAP. County Office staff have such nice, safe jobs — in air conditioned offices built in the last golden days before Proposition 13, insulated physically and metaphorically from the messy reality of schools, classrooms and children — that they would never risk their positions by being less than gentlemanly in their relations with school districts. Just say everything’s fine, and it will be!

    • el replied

      on April 22, 2014 at 12:42 pm

      My guess is that the county offices vary in their interactions with school districts. In the urban counties with large districts you may see that the county offices are completely deferential, but our rural county office is pretty hands on and actually even knows a fair amount about local conditions. That said, our rural county office of education oversees fewer total students and school sites than SFUSD.

      The effectiveness, value, and collaboratory nature of these plans is going to vary a lot by district size. The template that’s been created is not going to be meaningful for a district with hundreds of schools.

      • Paul replied

        on April 22, 2014 at 8:39 pm

        Hi, el.

        The rural counties comprise a tiny fraction of the state’s student population, but even so, I fear that the problem can occur there, too.

        I heard recently from a trusted friend who works as an administrator in a rural county about a case where the county superintendent was turning a blind eye and appointing people who didn’t know any better themselves. Oversight of the county’s school districts had suffered. It sounded as though this rural county office had turned into the same sort of country club that we see here in Bay Area counties.

        I wish that more county office (and district office) people cared about what actually happens in schools — as you clearly do!

        • el replied

          on April 23, 2014 at 8:29 am

          I know it’s just a tiny piece, but I like to bring up these counterexamples so that collectively we can understand what’s baked into the rules and what is a result of the specific people or the specific circumstances of a region. Education in California is incredibly diverse for both good and bad.

    • Gary Ravani replied

      on April 22, 2014 at 1:25 pm

      Paul:

      Here is Ed Code on grades:

      49066. (a) When grades are given for any course of instruction
      taught in a school district, the grade given to each pupil shall be
      the grade determined by the teacher of the course and the
      determination of the pupil’s grade by the teacher, in the absence of
      clerical or mechanical mistake, fraud, bad faith, or incompetency,
      shall be final.

      What kind of “grading policy” did you have in mind within those parameters?

      This puts a great deal of confidence in grades given by teachers. To what extent is that confidence justified? One good indicator can be found in an article about a recent study right on this site. The study confirms what has been known for some time; i.e., teachers grades, as indicated in students’ GPAs, are the best predictor of college success. Teachers’ grades outperform both the SAT and ACT in that regard. Certainty the CSTs have never been recognized as being helpful for instructional purposes, nor were they particularly valid and reliable; hence, we are spending tens of millions (perhaps far more) to implement new assessments. SBAC (or CAASP) promises to be better. At least the advertising says so. To suggest CST categorizations like “proficient” should outweigh confidence in teachers’ grades is unfounded empirically.

      There is considerable evidence that teachers need this autonomy, as given by Ed Code, in order to remain objective and independent from political, parental, and management pressure to change grades. Much of that autonomy will be lost if teachers lose their due process rights which protect them from those pressures.

      • Paul replied

        on April 22, 2014 at 8:21 pm

        Gary, I was well aware of my authority as teacher of record to determine grades. I had to remind a few parents, and at least one administrator, of the law.

        My interview anecdote is about trying to ferret out principals who interfere when teachers make the difficult decision to assign low grades. The hard work of telling children and parents the truth, of diagnosing, and of remediating, is not of interest to such “leaders”. [On the subject of policies designed to obscure student performance, do lookup the board policy on grading in Monterey — not the district in question, but an interesting case.]

        Standardized tests aren’t perfect. I’ve written here more than once that a student who did not know algebra could pass the Algebra I CST by using brute-force substitution. Still, the scores are not completely meaningless, and even you — who have criticized standardized testing, grade point averages, and other attempts at quantitative evaluation of students, and even prospective teachers — must realize that there is a happy medium between a near-100% passing rate for teacher-assigned, principal-influenced grades and a near-0% proficiency rate on the CST.

        Of course, the school’s SPSA and the district’s propaganda raved about efforts to close the achievement gap. I took the job, and soon found that those efforts were phony. There was, instead, strong pressure from administrators and colleagues to make things “easy”, to be “cool”, and to pass everyone. Citing the Ed. Code doesn’t do any good when you don’t have permanent status, when peacock-administrators control your evaluation, and when your colleagues used their seniority to foist the toughest courses and students on you.

        I left mid-year for another school, four of six math department colleagues left at the end of the year, and within three years, a broom-cleaning had eliminated the two long-standing VPs and shuffled the green principal off to a safe job as the district’s BTSA consortium rep.

        • Gary Ravani replied

          on April 23, 2014 at 1:12 pm

          No, I have not criticized using student GPAs. My example re college success was to emphasize to importance and accuracy of said GPAs. The research has demonstrated that over a number of years. And, by the way, that means the grades given by teachers (on a longitudinal basis) have been quite accurate whether the teachers are in Portland, Oregon, or Portland, Maine. It seems to cross all demographic boundaries also.

          You are right that if you are a temporary or probationary teacher, aka, without due process rights, the existence of the Ed Code provides little cover in the face of management pressure. Therefore the integrity of grades and GPAs needs to be protected by preserving the due process rights of permeant status teachers.

          I have observed a number of administrators over time who have tried to implement “grading policies,” but in the face of the Ed Code and permanent status for teachers, the “policies” have come to naught.

          I am not aware of anecdotal incidents in Monterey or elsewhere. It sounds like you had a difficult time at some school. That was unfortunate.

          I have not encountered teachers who found the CSTs “meaningful” for instructional purposes except, perhaps, for a few Math people. If that was your field that may explain our differing perspectives.

          • Paul replied

            on April 23, 2014 at 9:22 pm

            Gary, a few things:

            – You have often put down mine and other commentators’ concerns about low GPAs among teacher candidates (CTC program conditions + CSU policy allow a “C”); if GPAs are useful for K-12 students, why not for teachers, too?

            – I’m surprised that you have never met a single teacher who found CST data meaningful for instruction. Not using the data — especially cluster scores — is a shame, especially when systems like DataDirector and Measures make it easy for teachers to view their students’ past results. Perhaps it was a question of yours and your peers’ generation, philosophy, and/or computer skills, and of the data systems available when and where you taught. It’s certainly not a question of my teaching field. I have credentials in math, Multiple Subjects, and one world language language, authorizations in business and in another world language, and a bilingual authorization. While the CST isn’t perfect, I found that it provided some useful information in the math and Multiple Subjects contexts. When teaching world languages, I could also draw some parallels between ELA CST cluster scores and students’ reading, comprehension and writing skills in the world language. Many of my colleagues also used CST data.

            – As I said, my anecdote concerned a district other than Monterey. You had questioned whether grading policies other than the teacher’s own legal authority existed. You’ll find that Monterey has a board policy, applicable district-wide, that inflates grades. The minimum numeric grade for *not* completing an assignment is the “D” floor, not 0. Thus, failure is almost impossible. The district’s policy also requires teachers to confer with parents about what *teachers* (not students and/or parents) can do to boost students’ low grades. When it was passed, the policy made MPUSD a laughing stock (there were news articles and online comments). Board policies that require teachers to give credit for homework also serve to inflate grades.

          • Gary Ravani replied

            on April 24, 2014 at 1:13 pm

            The is an “apples and oranges” issue. Students GPAs have been established to accurately predict college success. There is no causal or correlational relationship I am aware of between “teacher success” and college GPA. The most comprehensive study I’m aware of, done by ETS, suggests there is very little difference between teachers’ academic prowess and that of there professions. All teachers have a BA after all, they are not academic laggards. Then there is the issue of defining “success” in teaching. The simplistic VAM has been debunked enough elsewhere to bother with here. There are many intangibles, at least in terms of what can be measured academically, to what makes a good teacher. There are dozens of books that attempt to define the qualities of good teaching, perhaps you have come up with the definitive answer?

            About CSTs and data: the CSTs are kaput and few are shedding any tears on that issue; and some folks just revel in spread sheets and data and some revel in working with kids and helping them learn and develop.. I suppose you could try and apply some kind of kinds of stereotypes about age to the issue, but i assume the wise would not go there.

  5. navigio said

    on April 21, 2014 at 1:36 pm

    Things would be a lot easier had districts properly followed their schools’ SPSA process. This is almost identical, just at a district level.

  6. Claire Castagna said

    on April 21, 2014 at 11:53 am

    For a district like ours with over 50% poverty and 40% EL that already has a quality LEA Plan, Technology Plan, Strategic Plan, Title III Plan and English Learner Master Plan, as well as parent participation committees such as DELAC, ELAC, DAC, Site Councils and our annual stakeholder Lyceum as well as benchmark assessments and data dashboards for all schools–the LCAP is little more than an exercise in cutting, pasting and narrative writing. Before requiring another plan–how about allowing districts to replace all those plans with the LCAP — get an electronic format that works– THEN ask districts to do the work. Until then–we already have good plans and good accountability systems…is there really a need for another one?

  7. Mike McMahon said

    on April 21, 2014 at 7:28 am

    While the State Board approved the template in January, CDE and West-Ed are still conducting technical advice webinars this month to establish further guidelines on completion of the LCAP template. So County Offices are still being vague in their direction on what satisfies a compliant LCAP. Finally, the LCAP template is designed for compliance which makes it very difficult for school districts to tell “their story” about what unique steps they are taking to address under served populations.

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