To ensure that LEAs provide mental health services as required, Education should, on an annual basis, identify LEAs with accumulated balances of mental health funding and analyze whether the LEA has had a corresponding drop in mental health service levels. For all LEAs that Education determines have both an accumulated balance and a corresponding drop in services, Education should follow up with the LEA to determine whether the LEA is meeting its obligations to provide mental health services to students as part of the special education program.
Fully Implemented. AB 114 fund data (funds provided and expended) from FY 2011-2012 through FY 2014-2015 was used to calculate a cumulative fund balance for each LEA. For each LEA with a 50 percent or greater AB 114 cumulative fund balance, their reported Mental Health (MH) related services data (California Special Education Management Information System series 500) was analyzed to identify LEAs with a decrease in MH related services. The data revealed that 15 LEAs had a 50 percent or greater AB 114 cumulative fund balance and a corresponding decline in MH related services. A survey instrument was sent to the 15 LEAs to identify the reasons behind the large fund balance and the decline in MH services. In addition, Education completed in-depth follow up with several of the LEAs to determine whether the LEAs were meeting their obligations to provide mental health services to students as part of the special education program. LEAs identified two instances that accounted for their fund balances and decline in services: (1) districts implemented school-wide MH interventions, taking care of MH needs in a general environment; and (2) smaller districts had small enrollments in MH services and the students left the district. In most cases the declines were in the single digits, showing that a significant decrease had not occurred for any particular LEA.
The data (both fiscal and services) and survey responses collected did not show a substantial decline in MH related services. Decreases in services were accounted for by year to year fluctuations in enrollment encountered by the respondents. The CDE has fully implemented the recommendation and determined that there is a lack of compelling evidence (there were only 15 out of 746 entities with a large fund balance and corresponding decrease in services) to warrant continuation of this activity in the future. No further action will be taken on this recommendation.
Education conducted an analysis that initially determined the cumulative fund balance in special education mental health service related funding by LEA. For each LEA that had a fund balance of 50 percent or more of the funding it had been provided since fiscal year 2011-12, Education then assessed whether the total number of mental health services that the LEA reported offering annually as of December 2011 were higher or lower than the total number of services provided annually as of December 2015. As it states in its response, Education then followed up with those LEAs that showed a cumulative fund balance of 50 percent or more that also had a lower number of services provided as of December 2015. Education asserts that the results of this analysis do not warrant continuing to perform the monitoring of fund balances and service levels on an annual basis as we recommended. Although there may still be some benefit to performing this type of analysis on a periodic basis, we consider this recommendation resolved.
Education is initiating a new monitoring activity this year that addresses elements of this recommendation. This new activity includes reviewing existing data Education receives from LEAs concerning their implementation of IEP-based mental health services (including the frequency of such planned services), reviewing each LEA's history in expending AB 114 funds, and identifying any LEAs that have large AB 114 fund balances and a concurrent decrease of reported planned IEP-based mental health services. Education will contact any LEAs identified as having large AB 114 fund balances and a corresponding decrease of reported planned IEP-based mental health services to obtain additional information. The information requested will concern the LEA's use of AB 114 funds and any other fund sources to provide IEP-based mental health services, and its recent history concerning the provision of IEP-based mental health services. Based on the information provided by the LEAs, Education will follow up as appropriate to obtain additional information and potentially initiate additional monitoring activities to address concerns about the LEA's use of funds or provision of IEP-based mental health services.
In its six month response, Education demonstrated that it had informed SELPAs about its plan to review fund balances. In this response, Education describes activities that, if performed, would likely implement our recommendation. This recommendation remains partially implemented. We look forward to Education reporting full implementation at its next update and submitting documentation supporting its implementation efforts.
Corrective Actions Taken: LEAs recently reported their expenditures of mental health funding for fiscal year 2015-16, and Education: (1) reviewed changes in LEA mental health fund balances; (2) is finalizing criteria for selection of LEAs for follow-up activities related to the delivery of related services and the use of fund sources to pay for them; (3) anticipates initiating follow-up activities with the selected LEAs within the next several weeks; and (4) informed the state's SELPA organization about the enhanced monitoring activity over mental health funding.
Education provided evidence that demonstrates it informed SELPAs about its plans to review fund balances.
Education concurs with this recommendation. LEA expenditures of mental health funding for fiscal year 2015-16 were recently reported and Education is currently reviewing changes in mental health fund balances to determine which LEAs would be appropriate for follow-up monitoring. Education anticipates initiating follow-up activities with the selected LEAs within the next few months.
†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.