The State Board of Education will take its first look Wednesday at proposed revisions to the much-criticized template for the Local Control and Accountability Plan.
The changes to the LCAP, a budget and planning document that every school district and charter school must create or update annually, are intended to make it better organized and easier to read. (See attachments 2 and 3 in the state board’s agenda for the draft.)
But in a letter to the state board last week, 21 advocacy groups serving low-income and minority students and parents criticized the plan’s failure to address the LCAP’s “single biggest problem”: a failure to demand clearer accounting for money that’s supposed to be used to improve the achievement of underperforming student groups.
The draft “falls short of the changes necessary to increase transparency and ensure equity,” said the July 8 letter from the groups that comprise the LCFF Equity Coalition. A revised LCAP template should also require that districts detail how they will help address student subgroups that have been designated poorly performing based on the indicators that the state board is expected to adopt as part of California’s new school and district accountability system, they said. This issue is not addressed in the draft.
The LCAP is a key component of the Local Control Funding Formula, in which the Legislature agreed to shift control over financial decisions to local districts and to direct more money for high-needs students: low-income children, foster and homeless youths and English learners. Districts are supposed to set goals and describe their actions and spending to respond to eight priority areas and to improve or add services and programs for the high-needs students who received additional money, called supplemental and concentration funding.
Since the passage of the funding law in 2013, school districts have written three LCAPs. School boards and administrators have complained that the template that districts must follow is disjointed, constraining, and, particularly for small districts with a limited staff, burdensome. Parent groups complained that some districts’ LCAPs mushroomed in length to hundreds of pages and that it was difficult to track expenditures.
The revised template may not reduce the length or complexity, but should make the document more logical and orderly. And the proposed inclusion of an executive summary, which some districts already have adopted, should satisfy many parents who just want to know the basics.
A committee of the organization representing county superintendents wrote the draft changes after soliciting a cross-section of views. Sandra Morales, assistant executive director of the California County Superintendents Educational Services Association, said discussions will continue during the next two months, before the state board adopts the template in September for the 2017-18 school year.
Among the proposed changes:
- The LCAP would become a three-year planning document, updated during the second and third years. Some districts had interpreted the law to require a rolling three-year document that required setting new goals every year.
- The annual update will be moved forward so that the public can quickly see whether the district took actions and met its improvement goals from the previous year.
- All of the instructions and guiding questions will be moved to an appendix.
- The section (page 4 of attachment 3) detailing the actions and expenditures for each goal has been reorganized to include which state performance indicator, such as suspension rates, is addressed and whether the actions and spending are new or a continuation of past actions.
- A new section focuses on supplemental and concentration funding: how much districts will receive and the percentage of increased or improved services that they must adopt based on the proportion of high-needs students enrolled. Districts then must explain how they plan to use the supplemental and concentration money.
While an improvement, a summary description won’t be sufficient, the equity coalition said. Analyses of LCAPs this year by the nonprofit advocacy groups the Education Trust-West, Public Advocates and Californians Together found that many districts did not say how they would spend significant amounts of supplemental and concentration funding, nor did they justify how they would use the money primarily for high-needs students. The LCAP should require more than a narrative, the equity coalition’s letter said. Each goal and action should specify whether supplemental and concentration dollars are included; otherwise, the public won’t know whether the money is going to students for whom the money is intended, the groups said.
Districts currently aren’t required to commit unspent supplemental and concentration dollars at the end of a fiscal year to high-needs students. The money becomes general funding that can be used for any purpose, as EdSource previously reported. The equity coalition urges the adoption of a “carryover box” that shows unspent supplemental and concentration funding that should be designated for use the following year.
Some county offices encourage districts to create a budget code for supplemental and concentration spending that enables them to track spending in their LCAPs. Some districts, like Berkeley Unified, on their own have put unspent supplemental and concentration money into a separate account for future use. But the state Department of Finance opposes the financial transparency changes that the advocacy groups and some Democratic legislators have proposed. The county superintendents’ association also disagrees.
The current and draft template reflects current law, Morales said. The Local Control Funding Formula permits districts to explain how they qualitatively improved programs and services in proportion to supplemental and concentration dollars districts received. This does not require a listing of expenditures; it can be done through a well-written narrative laying out plans for improvements for high-need students, she said. The proposed template encourages that.
John Affeldt, managing partner for Public Advocates, who helped draft the coalition letter, countered that a summary narrative alone will allow districts to obscure how they use the money.