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K–12 Local Control Funding
The State’s Approach Has Not Ensured That Significant Funding Is Benefiting Students
as Intended to Close Achievement Gaps

Report Number: 2019-101

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Appendix A

Scope and Methodology

The Joint Legislative Audit Committee (Audit Committee) directed the California State Auditor to select three large school districts and review information related to these districts’ LCFF funding, LCAPs, and measurement of educational success. Table A lists the objectives that the Audit Committee approved and the methods we used to address them.

Table A
Audit Objectives and the Methods Used to Address Them
1 Review and evaluate the laws, rules, and regulations significant to the audit objectives. Reviewed relevant laws, rules, and regulations.

Regarding LCFF, perform the following steps to the extent possible:

a. Identify and evaluate each school district’s methodology for distributing and spending LCFF funding on its students or at its schools.

b. For at least three fiscal years, examine each district’s total LCFF funding and expenditures and assess how they have changed over time under LCFF.

c. Determine for each school district and a selection of schools within each district the LCFF funding and expenditures by LCFF category and for English learners, youth in foster care, and those from households with low incomes, and determine whether the expenditures are appropriate.

  • Interviewed key staff and reviewed relevant documents—such as district budget handbooks and school board policies—to evaluate each of the three selected district’s (Clovis Unified, Oakland Unified, San Diego Unified) methodology for distributing and spending LCFF funding, including how it directs LCFF funding to specific school sites.
  • Obtained and analyzed the districts’ financial data from fiscal years 2015–16 through 2017–18 and other related documents to determine the extent to which each district tracked its supplemental and concentration funds.
  • Identified trends in each district’s total LCFF revenues since fiscal year 2013–14 using CDE’s funding data referred to as Funding Snapshots.
  • Analyzed expenditure information that the districts reported in their LCAPs from fiscal years 2014–15 through 2018–19—and compared that information to CDE’s Funding Snapshots—to determine whether districts included all of their supplemental and concentration funds in their LCAPs and whether they spent all of these funds they did include.
  • Selected and reviewed expenditures of supplemental and concentration funds that the districts reported in their LCAPs, including expenditures that applied to two specific school sites within each district, and assessed the reasonableness of the districts’ justifications for these expenditures.
3 Regarding LCAPs, perform the following steps:

a. Identify and assess the goals within each district’s accountability plan or elsewhere that are aimed at raising student achievement, especially those goals intended to benefit English learners, youth in foster care, and those from households with low incomes.

b. Review and assess whether each district’s most recent LCAP complies with applicable legal requirements, especially those requirements associated with measuring achievement and with helping students who are members of groups associated with chronically low academic achievement.

c. Make any necessary recommendations for improving accountability plans and student achievement levels, including, if warranted, additional goals that would be helpful to ensure improved achievement levels of these student groups.

  • Interviewed key staff at each selected district, at each county office, and at CDE about the LCAP development process and about CDE’s LCAP template.
  • Identified the goals within each selected district’s fiscal year 2018–19 LCAP and analyzed their alignment with the districts’ identified needs, planned services, and expected outcomes.
  • Assessed each district’s fiscal year 2018–19 LCAP to determine whether it complied with applicable legal requirements, and obtained additional documents to verify that districts followed key LCAP process requirements, such as holding public hearings to solicit comments.
  • Reviewed CDE’s fiscal years 2018–19 and 2019–20 LCAP templates to ensure that they met substantive legal requirements.
  • Reviewed documentation related to LCAP‑related complaints and settlement agreements to identify common concerns of stakeholders with LCAPs and to understand CDE’s position on these concerns.

Regarding the measurement of educational success, perform the following steps:

a. Identify and evaluate the measurements and measurement tools that each school district uses to assess success in educating its students, including English learners, youth in foster care, and those from households with low incomes.

b. Determine whether additional measurements would help the districts better ensure student success.

  • Interviewed key staff at each district to identify the district’s tools and practices for using measurements such as student outcomes, including how they use the dashboard.
  • Reviewed documents such as data guides and information on district webpages to analyze how each district uses measurements and measurement tools to assess success in educating its students.
  • Reviewed each district’s 2018–19 LCAP to document and assess the measurable outcomes each district reported.
  • Assessed CDE’s data guides, webpages, and other documents associated with the dashboard; interviewed relevant CDE staff about the process of developing and updating the dashboard; and documented revisions the State Board is considering for the 2019 dashboard.
  • Reviewed state data available on platforms such as the dashboard to assess how student outcomes have changed statewide and at our selected districts.
5 Review and assess any other issues that are significant to the audit.
  • Interviewed relevant CDE staff to obtain their perspectives on LCFF, LCAPs, and reporting outcomes.
  • Documented relevant items from the 2019–20 state budget—such as funding to plan for a longitudinal data system—and asked CDE staff for their perspectives when appropriate.

Sources: Analysis of the Audit Committee’s audit request number 2019‑101, as well as information and documentation identified in the table column titled Method.

Assessment of Data Reliability

The U.S. Government Accountability Office, whose standards we are statutorily obligated to follow, requires us to assess the sufficiency and appropriateness of computer‑processed information we use to support our findings, conclusions, or recommendations. In performing this audit, we relied on reports we obtained from CDE’s online LCFF Funding Snapshots, Dashboard, DataQuest, and California Assessment of Student Performance and Progress (CAASPP) systems. We used reports from the LCFF Funding Snapshots to identify the amounts of LCFF funding that districts received. Because the LCFF amounts in the Funding Snapshots for fiscal years 2015–16 through 2018–19 materially agreed with the LCFF revenue amounts included in the audited financial statements for the three districts we visited, we determined that the Funding Snapshots were sufficiently reliable for the purposes of this audit.

We used the reports from the other three systems—Dashboard, DataQuest, and CAASPP—to identify educational outcome information for certain student groups. We concluded that reports from these systems were of undetermined reliability. We did not perform an assessment of the reports from the Dashboard and DataQuest systems because the supporting documentation is maintained among California’s approximately 1,000 school districts, making accuracy and completeness testing impractical. To gain some assurance for these systems, we reviewed other information related to the educational outcomes of California’s students and found that it corroborated CDE’s data. In addition, we did not perform an assessment of the CAASPP reports because the system is paperless. We also did not perform a review of the controls over the system that produced these reports because of the significant resources required to conduct such an analysis. Although we recognize that any limitations that we identified in the reports may affect the precision of the numbers we present, there is sufficient evidence in total to support our audit findings, conclusions, and recommendations.

Finally, we tried to use data from the accounting systems of the three districts we visited; however, the districts do not consistently track LCFF funding in their accounting systems, as we explain in the Audit Results, and thus we could not rely on them for our audit work. Instead, we relied on each district’s LCAP for the expenditure information it reported. This information is of undetermined reliability.

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Appendix B

Trends of LCFF Funding

As the Introduction indicates, the State phased in full funding under LCFF over several years, increasing the amount of funds it apportioned to districts to close the gap between actual funding and the target funding level that state law establishes. CDE’s data show that when the State implemented LCFF in fiscal year 2013–14, it allocated local educational agencies about $40 billion, or just over 70 percent of the total target apportionment. The State increased funding levels in each year that followed until it fully funded LCFF for school districts in fiscal year 2018–19. In that year, it allocated a total of more than $62 billion in LCFF funding, of which districts received nearly $55 billion. Table B presents LCFF funding information for the three selected districts (Clovis Unified, Oakland Unified, and San Diego Unified) from fiscal years 2013–14 through 2018–19.

Table B
Three Districts’ LCFF Funding From Fiscal Years 2013–14 Through 2018–19
Fiscal Year 2013–14 2014–15 2015–16 2016–17 2017–18 2018–19
Clovis Unified LCFF Funding Over Time
Total LCFF Funded* $247,330,886 $275,018,846 $312,784,355 $335,191,456 $346,147,226 $372,565,134
Total Supplemental Budgeted in LCAP Unknown  8,833,000 17,864,615 23,139,241 25,532,165 29,585,921
Total Supplemental Expenditures in LCAP 2,700,000 8,252,783 18,118,972 23,267,119 25,713,144 29,272,423
Difference Between Budget and Expenditures in LCAP Unknown ($580,217) $254,357 $127,878 $180,979 ($313,498)
Oakland Unified LCFF Funding Over Time
Total LCFF Funded* $250,522,241 $281,576,262 $320,304,135 $337,219,507 $343,123,790 $359,487,786
Total Supplemental and Concentration Budgeted in LCAP 10,000,000 17,135,948 52,470,141 67,267,837 69,935,710 77,058,564
Total Supplemental and Concentration Expenditures in LCAP Unknown  Unknown  60,811,151 66,543,225 65,912,750 75,089,930
Difference Between Budget and Expenditures in LCAP Unknown  Unknown $8,341,010 ($724,612) ($4,022,960) ($1,968,634)
San Diego Unified LCFF Funding Over Time
Total LCFF Funded* $698,200,252 $779,743,332 $867,204,734 $893,104,625 $909,605,442 $948,944,564
Total Supplemental and Concentration Budgeted in LCAP Unknown  52,000,000 95,300,000 120,879,000 127,030,626 128,089,241
Total Supplemental and Concentration Expenditures in LCAP 20,400,000 52,000,000 96,986,200 121,173,699 123,521,697 128,089,240
Difference Between Budget and Expenditures in LCAP Unknown  –    $1,686,200 $294,699 ($3,508,929) ($1)

Source: Analysis of CDE’s LCFF principal apportionment data and districts’ LCAPs for fiscal years 2014–15 through 2018–19.

* Total LCFF does not include add‑on funding that districts received through the Targeted Instructional Improvement Block Grant program, the Home‑to‑School Transportation program, and the Small School District Transportation program.

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