Report 2016-136 All Recommendation Responses

Report 2016-136: School Violence Prevention: School Districts, County Offices of Education, and the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies (Release Date: August 2017)

Recommendation for Legislative Action

To ensure that students and staff are prepared to respond to violent incidents on or near school sites, the Legislature should require that safety plans include procedures, such as lockdowns, recommended by federal and state agencies. The Legislature should also require schools to hold periodic training and drills on these procedures.

Description of Legislative Action

Assembly Bill 1747 (Rodriguez) would require that the term "tactical responses to criminal incidents" in a comprehensive school safety plan include procedures related to individuals with guns on school campuses and at school-related functions, and that drills to prepare for active shooters or other armed assailants shall be based on the specific needs and context of each school and community. The bill would further provide that schools shall consider the most cost-effective method of preparing pupils and staff for an active shooter situation while balancing the physical and psychological risks associated with these drills.

  • Legislative Action Current As-of: March 2018

California State Auditor's Assessment of 6-Month Status: Legislation Introduced


Recommendation for Legislative Action

To ensure that districts and county offices are complying with state law each year, the Legislature should require CDE to conduct an annual statewide survey to determine whether schools have submitted plans and whether those plans have been reviewed and approved by their respective district or county office. The Legislature should also require CDE to issue an annual report detailing the survey's results.

Description of Legislative Action

Assembly Bill 1747 (Rodriguez) would require the California Department of Education (CDE), on or before January 1, 2020, and every other year thereafter, to conduct a statewide survey to determine whether schools have forwarded their comprehensive school safety plans and whether those plans have been reviewed and approved by either the school district or county office of education. On or before November 1, 2020, and every other year thereafter, CDE would be required to submit a report to the Legislature detailing the results of the survey.

  • Legislative Action Current As-of: March 2018

California State Auditor's Assessment of 6-Month Status: Legislation Introduced


Recommendation for Legislative Action

To ensure that districts and county offices are complying with state laws related to safety plans, the Legislature should add a requirement to the EAAP audit guide for districts and county offices to receive audits of their approval of safety plans.

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: March 2018

California State Auditor's Assessment of 6-Month Status: No Action Taken


Recommendation for Legislative Action

The Legislature should require that the partnership between CDE and DOJ periodically review safety plan requirements to ensure that the plans keep pace with evolving school environments and updated educational research.

Description of Legislative Action

Assembly Bill 1747 (Rodriguez) would require the School/Law Enforcement Partnership, comprised of the Superintendent of Public Instruction and the Attorney General, to periodically review comprehensive school safety plan requirements to ensure that they keep pace with evolving school environments and updated educational research.

  • Legislative Action Current As-of: March 2018

California State Auditor's Assessment of 6-Month Status: Legislation Introduced


Recommendation #5 To: Education, Department of

To ensure that districts and county offices properly review and approve safety plans as required, CDE should provide additional guidance regarding district and county office responsibilities under state law by updating and correcting the safety plan compliance checklist and making it available to all districts and county offices.

60-Day Agency Response

Fully Implemented. As stated in our original response, the safety plan compliance checklist was updated, corrected, and posted on the CDE's Web site at http://www.cde.ca.gov/ls/ss/vp/documents/schoolsafetyplanchklist.pdf in August 2017 and is now available to all districts, county offices of education, and the public.

  • Completion Date: August 2017
  • Response Date: November 2017

California State Auditor's Assessment of 60-Day Status: Fully Implemented


Recommendation #6 To: Education, Department of

To ensure that districts and county offices properly review and approve safety plans as required, CDE should provide additional guidance regarding district and county office responsibilities under state law by providing general direction to schools on what to include in their building disaster plans.

6-Month Agency Response

To further strengthen the general guidance already provided on building disaster plans, Education is updating the compliance checklist to include examples of building disaster plan procedures to consider when completing comprehensive school safety plans.

Additionally, the CDE issued a letter on February 1, 2018 reminding all county superintendents and charter school administrators to update and approve comprehensive school safety plans by March 1, 2018. The letter also included general guidance for emergency procedures and drills when developing school building disaster plans, including a list of various emergency situations for consideration, but not limited to the following: fire, relocation/evacuation, bomb threat, bioterrorism/hazardous materials, earthquake, flood, power failure/blackout, intruders/solicitors, weapons/assault/hostage, explosion, gas/fumes, and medical illness or injury (https://www.cde.ca.gov/nr/el/le/yr18ltr0201.asp).

  • Completion Date: February 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Although CDE has provided some information to school districts regarding what to include in schools' building disaster plans, it has yet to update the compliance checklist used by schools when updating their safety plans.

  • Auditee did not substantiate its claim of full implementation

60-Day Agency Response

CDE explored options to collaborate with other agencies to strengthen the general direction already provided for schools disaster building plans.

The CDE Coordinated School Health and Safety Office met internally with the School Facilities and Transportation Services Division to discuss building disaster plan concepts. In addition, CDE reached out to various entities, which provided the following expertise and input: (1) Cal OES - Staff agreed with CDE's interpretation regarding building disaster plans representing evacuation plans (EC 32282(B) Disaster procedures, routine and emergency, including adaptations for pupils with disabilities in accordance with the federal ADA of 1990). Cal OES also indicated that state buildings have evacuation plans but not building disaster plans; and (2) DGS - The office building manager provided their annually updated Emergency Operations Plan (EOP) to CDE. General elements of the EOP are consistent with those required by EC section 32282, and include calling for disaster procedures (routine and emergency), a crisis response plan (often called EOP), including adaptations for pupils with disabilities, and procedures for safe ingress and egress of pupils, parents, and employees to and from school sites. DGS' EOP Table of Contents specifies types of emergency situations and procedures that will serve as suggestions to LEAs developing building disaster plans. They include fire, relocation/evacuation, bomb threat, bioterrorism/hazardous materials, earthquake, flood, power failure/blackout, intruders/solicitors, weapons/assault/hostage, explosion/gas/fumes, and medical illness or injury.

CDE is updating the compliance checklist for a comprehensive school safety plan to include items, as suggested by the agencies contacted, for inclusion in the required building disaster plan. In addition, these items will be included in the CDE's annual reminder to LEAs regarding updating and approving school safety plans by March 1, 2018.

  • Response Date: November 2017

California State Auditor's Assessment of 60-Day Status: Pending

CDE is updating is compliance checklist to include items, as suggested by the Cal OES and DGS, for inclusion in the required building disaster plan. In addition, these items will be included in CDE's annual reminder to LEAs regarding updating and approving school safety plans by March 1, 2018.


Recommendation #7 To: Education, Department of

To ensure that districts and county offices properly review and approve safety plans as required, CDE should provide additional guidance regarding district and county office responsibilities under state law by providing information on best practices similar to those we discuss in this report for monitoring and approving safety plans.

6-Month Agency Response

The CDE issued a letter on February 1, 2018 reminding all county superintendents and charter school administrators to update and approve comprehensive school safety plans by March 1, 2018, and provided additional guidance and updates, including effective best practices (https://www.cde.ca.gov/nr/el/le/yr18ltr0201.asp).

  • Completion Date: February 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Fully Implemented

We reviewed the letter reminding all county superintendents and charter school administrators to update and approve comprehensive school safety plans by March 1, 2018 and found it included appropriate guidance. However, we expect CDE to provide regular updates and guidance to schools.


60-Day Agency Response

The CDE contacted Rocklin Unified School District (identified in the audit report as having met the requirements related to school based violence readiness and prevention) regarding best practices related to developing guidance to assist schools and districts in monitoring and approving safety plans, and was briefed on their school safety plan monitoring and approval procedures. These model practices will be included in the CDE's annual reminder to LEAs regarding updating and approving their school safety plans by March 1, 2018.

  • Estimated Completion Date: March 2018
  • Response Date: November 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #8 To: Education, Department of

To ensure that districts, county offices, and schools receive guidance on a variety of safety issues and to comply with state law, CDE and DOJ should resume their partnership activities, as required by state law. Further, the partnership should update the 2002 handbook, "Safe Schools: A Planning Guide for Action," and distribute it to all districts and county offices. If CDE or DOJ determine the need for additional funds to implement the legislative recommendations or to reestablish the partnership's activities, they should request those funds from the Legislature.

6-Month Agency Response

The CDE and DOJ discussed, and will continue to confer on, the current School Law Enforcement Partnership statute.

The DOJ has agreed to participate in the CDE SPI School and Community Safety Advisory Committee and in the planning of CDE's pre-conference session at the 9th Annual Safe Schools Conference in July, 2018. Additionally, the CDE has offered to participate in relevant DOJ meetings and committees.

  • Estimated Completion Date: December 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The CDE and DOJ discussed, and will continue to confer on, the current School Law Enforcement Partnership statute. Future discussions will include potential next steps and viability of implementation given the absence of funding and staff for the program.

The CDE also researched the cost to update the 2002 School Safety Planning Handbook, which includes additional staff resources, convening school safety subject matter experts to recommend content, contracting a professional writer, editing and design, and preparation for online posting. The estimated cost is approximately $350,000; funding will be needed from the Legislature in order for the CDE to accomplish this activity.

  • Estimated Completion Date: December 2018
  • Response Date: November 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #9 To: Justice, Department of

To ensure that districts, county offices, and schools receive guidance on a variety of safety issues and to comply with state law, CDE and DOJ should resume their partnership activities, as required by state law. Further, the partnership should update the 2002 handbook, "Safe Schools: A Planning Guide for Action," and distribute it to all districts and county offices. If CDE or DOJ determine the need for additional funds to implement the legislative recommendations or to reestablish the partnership's activities, they should request those funds from the Legislature.

6-Month Agency Response

The Superintendent of Public Instruction has formed a Statewide School and Community Safety Advisory Committee.

DOJ will be participating in the committee. In addition to DOJ's law enforcement/community efforts, the committee is comprised of CDE Staff, educators, diverse superintendent and administrator organizations, representatives from State Parent Teacher Association, California School Employee Association, California School Board Association, mental health subject matter experts; Governor's Office of Emergency Services; community college safety coordinators; county offices of education; fire and law enforcement first responders; state, county, and local governmental and non-governmental entities; recreation and parks representatives; and others.

The committee will identify gaps and issues in school safety plans, identify and share effective practices that leads to enhanced relationships and networks between and among K-12 educators including superintendents, administrators, teachers, school nurses, counselors and mental health specialists, and classified staff.

The committee efforts will strengthen existing activities and identify new methods so that the school districts/boards, county offices of education, and school site personnel receive guidance in the development of their respective school safety and crisis response plans to ensure students and staff are kept safe in the event of an emergency involving active shooter incidents.

  • Estimated Completion Date: 8/31/2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The DOJ has contacted CDE to discuss the history of the program and any associated resources. Unfortunately, there are no current resources available for the program at CDE or DOJ. Given this, CDE and DOJ are discussing the State Auditor's recommendation and how to move forward.

  • Estimated Completion Date: unknown
  • Response Date: October 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #10 To: Kern County Office of Education

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1 each year, the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking systems and safety plan templates.

6-Month Agency Response

Starting in September 2017, a leadership committee was established to supervise and monitor the development of the Comprehensive School Safety Plan for each of the court and community school sites in Kern County.

The first step was to establish Safety Planning Committees (SPC) at each school site which consisted of an administrator, classified staff, teacher, parents, students, and other support staff. Some of the SPC's included law enforcement personnel as well. However, each school site safety plan was developed in consultation with law enforcement, even if they were not part of the SPC.

Meetings facilitated by the site SPC were scheduled at each school site over the next several months. The purpose of the meetings were to develop and review the Comprehensive School Safety plan. The development of each school site plan was developed in accordance to the Compliance Checklist for a Comprehensive School Safety Plan provided by the California Department of Education. A final meeting to which all staff, parents, students, and community members, including the mayor of the city, were invited, was held at each site to allow for public input.

Upon completion of the School Safety Plans, the SPC submitted the plans to the designee (Carlos Rojas) at the county office of education for approval. Supporting documents will be emailed to Aaron Fellner at aaronf@auditor.ca.gov today.

  • Completion Date: March 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Kern County Office of Education schools have created school safety plans for the 2018 school year and submitted them for approval. However, it has yet to develop any procedures to ensure that this happens on an annual basis, such as a document tracking system. Further, it has yet to adopt safety plan templates to help ensure schools include all the elements required by state law.

  • Auditee did not address all aspects of the recommendation

60-Day Agency Response

The plan for implementing the recommendation is outlined in detail on the document emailed to aaronf@auditor.ca.gov on 10/20 at 7:47 a.m. PST. We have identified the specific tasks, staff responsible, and dates to be completed to ensure full implementation of the recommendation by March 1. 2018.

  • Estimated Completion Date: March 1, 2018
  • Response Date: October 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #11 To: Placer County Office of Education

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1 each year, the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking systems and safety plan templates.

6-Month Agency Response

PCOE has completed the annual update of the Comprehensive Safe School Plans (CSSP) for the schools it operates in accordance with the project plan provided on October 27, 2017, and has met the recommendations set forth by the California State Auditor's Office (CSAO). PCOE completed Recommendation 11 through the following steps:

- PCOE redeveloped its digital CSSP template to meet the unique needs of PCOE schools', students, parents, and staff. School site plans are identified individually by the County-District-School (CDS) identification numbering system.

- All CSSPs contain the policies and information required by education code and state law. In addition, 11 Emergency Procedure Manuals were created for each site containing confidential tactical procedures for use in crisis situations.

- Each School Site Council/Safety Committee analyzed and updated its CSSP, conferred with law enforcement and held a site-based public hearing. Each School Site Council/Safety Committee certified to the County Superintendent's office the fulfillment of the requirements for its CSSP by council/committee adoption.

- In addition to the required components of a CSSP, each site developed written safety procedures to accommodate students and persons with disabilities for emergency situations.

- The Placer County Superintendent of Schools and staff reviewed and approved each site CSSP prior to March 1, 2018.

- Progress and continued improvements will continue to be communicated to the CSAO on an annual basis.

  • Completion Date: February 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Fully Implemented

Placer County Office of Education (PCOE) schools completed all their school site safety plans, using PCOE's safety plan template. Further, PCOE has implemented a document tracking system to ensure all its schools submit their safety plans prior to the March 1 deadline each year.


60-Day Agency Response

Following is a summarized project plan to meet recommendation #11 from the State Audit Report

- Communicate recommendation progress to the CSAO within 60, 180, and 365 days from August 31, 2017. Annual communication will then occur over the next five years.

- Redevelop the Safe School Plan electronic template to fulfill the unique needs of PCOE schools', students, parents, and staff, while meeting state requirements. School site plans will be identified by the County-District-School (CDS) identification numbering system (Sept. - Nov. 2017).

- Assemble all required policies and information inside the Safe School Plan template in order to provide a readily available public document. Some components of these plans will remain as confidential when they provide tactical details (Sept. 2017 - Feb. 2018).

- Require each school as identified by CDS code to analyze and update its Safe School Plan annually through a School Site Council/Safety Committee and certify to the County Superintendent's office the fulfillment of the requirements (Dec. 2017 - Feb. 2018).

- Develop written safety procedures to accommodate students and persons with disabilities based on current tactical practice (Sept. 2017 - Feb. 2018).

- Continue to practice and train students and staff on emergency procedures, including violent threat procedures utilizing federal and state resources, as well as current crisis response plans (Sept. 2017 - June 2018).

Documents showing current progress will be shared with the CSAO through the requested communication channel.

  • Estimated Completion Date: 3-1-2018
  • Response Date: October 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #12 To: San Bernardino County Superintendent of Schools

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1 each year, the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking systems and safety plan templates.

6-Month Agency Response

The plan for implementation is outlined in the documents and attachments emailed directly to Aaron Fellner.

  • Estimated Completion Date: August 31, 2018
  • Response Date: March 2018

California State Auditor's Assessment of 6-Month Status: Partially Implemented

SBCOE provided our office with a draft safety plan template for eventual use at all of its schools. It also provided evidence that staff attended two active shooter trainings.


60-Day Agency Response

Documentation will be sent via email to Aaron Fellner, Audit Supervisor.

  • Estimated Completion Date: June 30, 2018
  • Response Date: October 2017

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #13 To: San Bernardino City Unified School District

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1 each year, the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking systems and safety plan templates.

6-Month Agency Response

ALL CSSP's HAVE BEEN SUBMITTED, REVIEWED AND APPROVED USING DOCUMENT TRACKING SOLUTIONS.

  • Completion Date: March 2018
  • Response Date: February 2018

California State Auditor's Assessment of 6-Month Status: Fully Implemented

SBCUSD provided us with the safety plan template used at all of its schools. In addition, it already utilizes a document tracking system.


60-Day Agency Response

The SBCUSD has trained all school sites on the u of Document Tracking Services DTS) as the means of completing. The individual school sites are currently conducting their planning meetings with SSC and other stakeholders to meet our internal deadline of January for submission to the school district.

  • Completion Date: July 2017
  • Response Date: October 2017

California State Auditor's Assessment of 60-Day Status: Partially Implemented

SBCUSD has implemented a document tracking system and created a template for schools to use when creating safety plans. The recommendation will be fully implemented when all schools in the district submit safety plans, and those plans are approved by the district on or before March 1, 2018.

  • Auditee did not address all aspects of the recommendation

All Recommendations in 2016-136

Agency responses received are posted verbatim.