Report 2012-108 Recommendation 15 Responses

Report 2012-108: School Safety and Nondiscrimination Laws: Most Local Educational Agencies Do Not Evaluate the Effectiveness of Their Programs, and the State Should Exercise Stronger Leadership (Release Date: August 2013)

Recommendation #15 To: Sacramento City Unified School District

To ensure that it is effectively preventing and addressing incidents of discrimination, harassment, intimidation, and bullying in its schools, Sacramento City Unified should ensure that school sites follow the complaint procedures established in its policies.

Agency Response*

The District has continued its efforts to train all site leadership regarding its responsibilities to investigate all complaints of discrimination. During its 2017 annual required summer trainings, the District Legal Services and Student Hearing Departments presented a "Student Harassment Training" for all administrators. This training included complaint investigation and documentation procedures. The Human Resources Department has continued its annual fall "one-stop" visits to school sites and departments, where a review of complaint procedures and resolution strategies are reviewed.

For significant or formal complaints, the Student Hearing Department oversees student discrimination complaint investigations. This school year, the Student Hearing Department Director/Student Non-Discrimination Coordinator and In House Counsel will provide additional site based trainings to review anti-discrimination procedures, including the requirements of reporting and forwarding same to Student Hearing/Student Non-Discrimination Coordinator's Department for oversight pursuant to Administrative Regulation 5145.3, pg. 5, Investigations of Complaints, no. 11. The Student Hearing Department/Student Non-Discrimination Coordinator maintains copies of such complaints/resolutions and shall track all complaints and resolutions through its data base system. The District, through the Student Hearing Department, shall utilize the data tracking system to assess patterns that require site audits and provide necessary remedies, and additional trainings as required.

In addition, the District office has for many years used standardized processes to collect, monitor and review any and all Uniform Complaints (which all complainants of discrimination are offered pursuant to existing policy and law.)

  • Response Type†: Annual Follow Up
  • Completion Date: September 2017
  • Response Date: November 2017

California State Auditor's Assessment of Status: Pending

During the audit we noted that the district provides an annual training to its school site personnel; however, our audit determined that the training did not effectively "ensure that school sites follow the complaint procedures established in its policies." Although the district provided evidence of its annual training and annual site visits, it did not provide sufficient evidence to demonstrate that these efforts adequately address the findings described in the audit report.

In a follow-up conversation, the district's in-house counsel noted that the district plans to institute annual audits of sites to help ensure ongoing compliance.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The district, through the Human Resources Department, has continued its annual fall "one-stop" visits to school sites and department, where a review of complaint procedures and resolution strategies are discussed along with staffing and certification analysis. Additionally, we work directly with school leadership to guide, assist in performance of investigation activities toward resolution, as needed. The attached documents show various methods that are used to schedule these meetings and the information shared with site administrators during the visit.

  • Response Type†: Annual Follow Up
  • Completion Date: September 2015
  • Response Date: November 2016

California State Auditor's Assessment of Status: Not Fully Implemented

Sacramento City Unified provided its schedule of school site visits, which are supposed to cover "sexual harassment, discrimination, and prevention training" and the district's complaints and grievances process. However, it did not provide sufficient evidence to demonstrate that these school site visits adequately address the findings described in the audit report.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The district has continued its full implementation of this recommendation since the initiation in August 2014. The District conducted is annual harassment prevention training on August 2015 to site administrators, supervisors, and managers which included addressing complaints in accordance with district processes and procedures. The District, through the Human Resources Department (HR Directors), continues its annual fall "one-stop" visits to each school site and department where, review of complaint procedures and resolution strategies are discussed along with staffing and certification analysis. Additionally, we work directly with school leadership to guide, assist, in the performance of investigation activities toward resolution as needed.

Complaint instructions to Investigators (Attachment (1)

Time frame to file:

http://www.scusd.edu/sites/main/files/file-attachments/annual_notification_letter_of_ucp-2015-16_0.pdf

  • Response Type†: Annual Follow Up
  • Completion Date: August 2015
  • Response Date: October 2015

California State Auditor's Assessment of Status: Partially Implemented

The district has continued to claim that it has fully implemented this recommendation; however, it has not provided sufficient evidence to demonstrate its efforts to ensure school sites' compliance with complaint procedures established in its policies.

During the audit we noted that the district provides an annual training to its school site personnel; however, our audit determined that the training did not effectively "ensure that school sites follow the complaint procedures established in its policies." Although the district's annual notification does well to describe the complaint process timelines, the notification does not demonstrate that the district has performed the "one-stop visits" it described in its response.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The district conducts annual harassment prevention training to site administrators, supervisors, and managers which includes addressing complaints in accordance with district processes and procedures. Staff from the Bullying Prevention Office, Student Behavior Office and the Human Resources Department work closely with school leadership to ensure adherence to related policies.

  • Response Type†: 1-Year
  • Completion Date: August 2014
  • Response Date: August 2014

California State Auditor's Assessment of Status: No Action Taken

The district did not provide sufficient detail or evidence to support that it has taken any corrective actions to implement the recommendation. During the audit we noted that the district provides an annual training to its school site personnel; however, our audit determined that the training did not effectively "ensure that school sites follow the complaint procedures established in its policies." In addition, the district failed to indicate how it works closely with school leadership to implement the recommendation.

On September 30, 2014, we notified Sara Noguchi, Sacramento Unified's chief accountability officer, that we assessed the district's implementation status as "No Action Taken" for the reason stated above.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The district failed to update its response in the recommendations database.

  • Response Type†: 6-Month
  • Estimated Completion Date: 8/20/2014
  • Response Date: August 2014

California State Auditor's Assessment of Status: No Action Taken

Despite our requests, Sacramento City Unified failed to update its response in the recommendations database.


Agency Response*

The District plans to introduce new software to monitor complaint activities including training for potential investigators of record.

  • Response Type†: 60-Day
  • Estimated Completion Date: June 2014
  • Response Date: December 2013

California State Auditor's Assessment of Status: Pending

The district's response indicates that it is currently in the process of implementing this recommendation.


All Recommendations in 2012-108

†Response Type refers to the interval in which the auditee is providing the State Auditor with their status in implementing recommendations made in an audit report. Auditees must submit a response regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year or subsequent to one year.

*Agency responses received after June 2013 are posted verbatim.


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