In exchange for local flexibility, accountability plans will require work

November 23, 2015

John Affeldt

I have a thought for school district staff, board members and others characterizing the process for developing Local Control Accountability Plans (LCAPs) as too time-consuming, tedious and cumbersome.

Quit your belly-aching!

Districts and other local educational agencies have just been relieved of a slew of bureaucratic compliance mandates tied to dozens of old state categorical programs. Those mandates required hours of accounting, tracking, reporting and general “bean-counting” of dollars spent. They limited district spending to the multiple, mostly narrow confines of the various categoricals and carried, as well, the threat of losing funds because someone bean-counted wrongly. Now districts can meld the old pots together to spend the funds much more flexibly, free from the strict and multiple prerogatives of Sacramento. As a member of my local school board, I have seen firsthand how this can work better.

The deal – that many folks now seem to be conveniently forgetting – was that in exchange for dropping all of that work and for having all this new flexibility districts would be fully transparent around their spending and engage community stakeholders in spending decisions.

Guess what? That is going to take some real work, people.

From some who merely see it as “compliance” work, I sense a failure of imagination. The intent of the Local Control Funding Formula (LCFF) is that the LCAP serve as a living, breathing, continuously improving “comprehensive planning tool” (see LCAP template, page 1), developed and implemented with the school community. Ongoing, strategic planning and effective community engagement are two things districts have not historically been asked to do. Faced with these new expectations, it is easier to treat the LCAP as an exercise in filling in boxes and checking off stakeholder contact compliance. Instead, we ought to be figuring out how to make the deal work as intended.

For its part, if the state believes its new “local control” mantra, it will need to seriously invest in expanding both district and local stakeholder capacity to engage in the new strategic planning dialogue. That means the state will need to improve the quality of the planning, the depth and reach of the engagement, the readability of the LCAP and the ability of local communities to understand what they find there. The PTA is calling for a billion-dollar investment in parent engagement. That would be a start.

Length and accessibility of the LCAP to the lay person are issues, no doubt. However, readability can be solved with executive summaries, better technical and graphic LCAP design, electronic templates and progressive layers of links to more detail for the more interested and engaged reader. For example, the length of most LCAPs can be cut down by about a third if actions, expenditures and measurable outcomes for years two and three were reported only where different from year one; 90 percent of the time, it seems, the latter two years are merely cut and paste jobs. Length could be further reduced significantly if the Annual Update section (i.e., whether you did what you said you were going to do this year) were integrated into the same section as your plan for next year. Interactive hyperlinks could yet further promote full transparency and avoid the urge to dumb down information. (Along these lines, what a disappointment it was for many at the last state board meeting to see the new “electronic template” was only “electronic” for districts.  This will make the process easier for districts to fill out, but it will make it no easier for community readers who will see exactly the same so-last-century pdf document that they do currently.)

An even greater threat to the full transparency promised by the LCFF, however, is the failure of most districts to properly articulate all their LCFF spending and to identify and justify the uses of their supplemental and concentration spending on high-needs students as required. Our analysis of dozens of LCAPs at Public Advocates mirrors that of others by the ACLU and Californians Together in revealing these significant shortcomings.

By way of just one example, Long Beach Unified’s LCAP – which was approved by the L.A. County Office of Education – discusses some $85 million of districtwide and schoolwide supplemental and concentration spending on a single page.

It is only able to do so because it refers very generally to spending actions – e.g, “college and career readiness efforts,” “technology infrastructure and support,” “foster youth services” – without ever explaining exactly what that spending is, how much it is or why it is principally and effectively directed to serve high-needs students. No matter how much an LCAP template might be improved upon, it won’t be worth the paper in the printer if the state and our county offices fail to issue the direction needed to bring to life the equitable spending plans LCFF promised.

Now, two years in, it is clear that the next steps for making LCFF real is a serious investment in district and stakeholder planning and engagement capacity, a functional and readable LCAP, and a state infrastructure that actually ensures the spending transparency promised is delivered. What we should not do is undermine the deal for full transparency and robust engagement with short blurbs, vague generalizations and more hidden spending.

Recall that we ended up with so many categoricals because districts abused their flexibility and too often neglected the neediest students. I think most districts genuinely want to make LCFF work, but if too many push for or lapse into the old ways without full transparency and robust engagement, then, I predict, this new experiment is likely to prove very short-lived indeed.


John Affeldt is Managing Attorney at Public Advocates Inc., a nonprofit law firm and advocacy organization in San Francisco.  He is also President of the Emery Unified School District Board.

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