With marching orders from the Legislature to create a parent-friendly document, the California Department of Education is in the final throes of designing another version — its fourth in six years — of the form that districts must use to explain how they’ll use funding from the Local Control Funding Formula. The formula covers about 80 percent of money they get from the state.
Lawmakers ordered the department to make the Local Control and Accountability Plan, or LCAP, shorter, clearer and easier to read after receiving constant complaints. Parents and members of the public complained that the annual plans had grown in many cases to hundreds of pages in length with dense prose and off-putting acronyms.
District and county office of education administrators complained, too, for a different reason: They said that requirements from the department, the State Board of Education and the Legislature turned the LCAP into a turgid compliance document instead of a useful guide to improvement.
The state board will adopt the new LCAP template in January for use in 2020-21. Modified after dozens of presentations over the past six months, the final version will be a notable improvement, most everyone agrees. Basic changes, like moving the lengthy instructions out of the LCAP template, grouping yearly updates together and putting expenditures into readable tables should cut the length by more than half and make for a more logical presentation.
Districts explicitly will be directed to use simple language, particularly in the opening sections, where they must summarize the LCAP, identify achievement gaps among student groups and cite areas of success and those most needing improvement.
Instead of just documenting how and how often districts consulted with the community on the LCAP, districts will be asked to explain specifically how each group — parents in general, English learner parents in particular, teachers, principals, students and others — influenced the development of the LCAP.
Districts will have the option of concentrating on “focus goals” deserving the most attention and resources, instead of a lengthy list of goals responding to the nearly two dozen metrics the Legislature requires districts to track. The latter approach created the impression that every goal was equally important, resulting in a scattershot approach to improvement.
“The direction is positive. Most everything is an improvement,” said Joshua Schultz, deputy superintendent of the Napa County Office of Education and a member of an advisory committee on the new design. “Having expenditure tables will reduce the length and make it easier to find information.”
Where opinions diverge is whether a shorter, more readable LCAP will also be more transparent — specifically whether the public will find it easier to track the additional money that the funding formula provides for high-needs students — low-income students, English learners and homeless and foster youths.
Accounting for this money, called supplemental and concentration funding, is a primary requirement of the LCAP. But how to monitor it has been a continuing source of contention and frustration for parents and student advocacy groups.
The latest LCAP format won’t end the debate and probably won’t end the complaints and lawsuits that organizations like the ACLU and the nonprofit law firm Public Advocates have filed. It will ask districts to more explicitly justify and describe how they will spend supplemental and concentration money.
But, as in the past, the new LCAP will stop short of demanding that districts give an itemized accounting of supplemental and concentration spending. That’s because the Legislature and the state board have been intentionally ambiguous on this point, dating back to the passage of the funding formula in 2013.
A shift from ‘categorical’ funding
The Local Control Funding Formula statute says that districts must increase or improve programs and services in proportion to the extra supplemental and concentration dollars they receive. Under the formula, for example, a district in which low-income children and the other designated high-needs groups make up 70 percent of enrollment will get 22 percent more funding.
How they spend the funding — hiring extra counselors, social workers, tutors and classroom aides or adding instructional time each day or summer programs — is up to them. But the extra programs and services must be tied to a measurable goal and then used for high-needs student groups.
The rationale for not requiring a detailed list of supplemental and concentration spending is that the LCAP is intended to be a strategic plan, not a budget document, and the focus should be on the process and strategies for improvement, not on dollars.
Supplemental and concentration dollars technically are not a “categorical fund” with strict regulations and separate accounting. Give districts latitude to spend state, federal and local dollars, longtime state board member Sue Burr said during a board meeting in September and “let’s not put kids in little boxes” based on where the money came from.
The problem with isolating supplemental and concentration money, Schultz added, is that districts would treat it as if it were categorical funding, with an inflexible mindset that says, “once money becomes locked in, it cannot be changed.”
A few districts, like Berkeley Unified, assign their own accounting code to supplemental and concentration expenditures to ensure transparency, but the state has declined to do so, preventing reviewers from easily determining statewide spending patterns and making district comparisons.
Since the funding formula was enacted, supplemental and concentration funding has grown from $1.5 billion to $9 billion, said Rob Manwaring, a consultant to the nonprofit research and advocacy organization Children Now. “So what’s being done with the extra $7.5 billion? We don’t know.”
Compounding the challenge is that districts where high-needs children make up more than 55 percent of students can use supplemental and concentration funding for districtwide purposes — whether for teacher training, more staffing or programs to reduce absenteeism.
However, districts must verify that the funding still will be “principally directed” to the high-needs students and will be an effective use of the funding. Critics say many districts either don’t cite a justification or are vague. Advocacy groups in recent letters are calling on the department and the state board to demand fuller and more precise explanations (see here for Children Now and here for the Equity Coalition).
Under 2015 guidance from then-Superintendent of Public Instruction Tom Torlakson, districts facing teacher shortages and large staff turnover because of uncompetitive pay scales can use supplemental and concentration funding for across-the-board raises — if they can make a case for it — something that is rarely if ever done.
With districts experiencing large mandated increases in staff pension costs and special education expenses, advocacy groups have speculated that districts have been diverting supplemental and concentration dollars to cover basic expenditures.
“Clearly there is encroachment and if you forced districts to show that, they’d be in a bind” with evidence that they are “doing something illegal,” said Carrie Hahnel, an education consultant and former co-director of the Education Trust-West.
Even with its shortcomings, longtime observer Michael Fullan, a Canadian authority on school reform, concluded in a recent report — and educators he spoke with agreed — that the Local Control Funding Formula continues to hold great promise. Of the LCAP, he wrote, “The template has been modified over the past few years to simplify it, yet it is still far from being simple, agile and usable as a strategic plan.”
Schultz said he hopes that the revised version could make a difference, that “those who grumbled that the LCAP has been just a compliance exercise will see this as less of a burden and an opportunity to implement good practices for what is best for kids.”
Then, tempering expectations, he said, “Sometimes at the policy level, there is an unrealistic expectation changing a form will magically change practice.”
A new form alone, he said, “will never be the answer.”