FCMAT
Evaluation of California Department of Education Oversight of the Plumas Unified School District Report
evaluation of CDE oversight
California Department of Education
December 1, 2025
Oversight of the Plumas
Unified School District
Michael H. Fine
Chief Executive Officer
December 1, 2025
Tony Thurmond, California Superintendent of Public Instruction
California Department of Education
1430 N Street
Sacramento, CA 95814
Dear Superintendent Thurmond:
In August 2025, the California Department of Education (CDE) and the Fiscal Crisis and Management
Assistance Team (FCMAT) entered into an agreement for FCMAT to conduct an evaluation of the CDE’s
oversight of the Plumas Unified School District, in accordance with statute. The agreement states that
FCMAT will perform the following:
1. Prepare an initial analysis of the state superintendent of public instruction’s fiscal oversight
provided to the Plumas Unified School District using FCMAT’s County Superintendent of
Schools Evaluation Tool, and make recommendations for improvement, if any.
This report contains the FCMAT study team’s findings and recommendations from the initial evaluation of
the state superintendent’s oversight of the Plumas Unified School District.
FCMAT appreciates the opportunity to serve the state superintendent of public instruction and the CDE and
extends thanks to its staff for their cooperation and assistance during this review.
Sincerely,
Michael H. Fine
Chief Executive Officer
Michael H. Fine • Chief Executive Officer
1300 17th Street – City Centre, Bakersfield, CA 93301-4533 • Tel. 661-636-4611 • Fax 661-636-4647
www.fcmat.org
Table of Contents
Table of Contents
About FCMAT ..................................................................................................2
Introduction ......................................................................................................4
Background ...............................................................................................................4
About this Study and Report ...............................................................................5
Study Team ................................................................................................................5
California Department of Education Oversight Evaluation Tool ..................5
Summary ........................................................................................................... 7
Findings ............................................................................................................11
Conclusion .....................................................................................................24
Appendix ........................................................................................................25
Study Agreement ...................................................................................................25
Fiscal Crisis and Management Assistance Team California Department of Education 1
About FCMAT
About FCMAT
Purpose and Services
FCMAT was created in 1991 by the California Legislature to help California’s TK-14 local educational agen-
cies (LEAs) avoid fiscal insolvency. Today, FCMAT helps LEAs identify, prevent and resolve financial, man-
agement, program, data, and oversight challenges; provides professional learning; produces and provides
software, checklists, manuals and other tools; and offers other related school business and data services.
FCMAT may be asked to provide fiscal crisis or management assistance by a school district, charter school,
community college, county office of education, the state superintendent of public instruction, or the
Legislature.
When FCMAT is asked for help with management assistance or a fiscal crisis, FCMAT management and
staff work closely with the requesting LEA to meet their needs. Often this means conducting a formal
study using a FCMAT study team that coordinates with the LEA for on-site fieldwork to evaluate specified
operational areas and subsequently produces a written report with findings and recommendations for
improvement.
For more immediate needs in a specific area, FCMAT offers short-term technical assistance from a
FCMAT staff member with the required expertise.
To help meet the need for qualified chief business officials (CBOs) in LEAs, FCMAT offers four different CBO
training and mentoring programs that consist of 11 or 12 diverse two-day training sessions over the course
of a full year.
For agencies with professional learning needs, FCMAT offers workshops on specific topics. Popular topics
include associated student body operations, use of FCMAT’s Projection-Pro online financial forecasting
software, use of FCMAT’s Local Control Funding Formula (LCFF) Calculator, and data reporting for the
California Longitudinal Pupil Achievement Data System (CALPADS). FCMAT staff and management also
frequently make presentations at various professional conferences.
The California School Information Services (CSIS) service of FCMAT helps the California Department of
Education (CDE) operate CALPADS; helps LEAs learn about CALPADS, resolve data issues and meet
reporting requirements; provides LEAs with training and leadership in data management; developed and
continues to host and improve the Standardized Account Code Structure (SACS) web-based financial
reporting system for all California LEAs; and provides ed-data.org, which gives educators, policymakers,
the Legislature, parents and the public quick access to timely and comprehensive data about K-12 educa-
tion in California.
Since it was formed, FCMAT has provided LEAs with the types of help described above on more than 2,000
occasions.
FCMAT’s administrative agent is the Kern County Superintendent of Schools. FCMAT is led by Michael
H. Fine, Chief Executive Officer, and is funded by appropriations in the state budget and modest fees to
requesting agencies.
Workshop schedules, manuals, presentation slide decks, Projection-Pro software, the LCFF Calculator, past
reports, an online help desk, and many other resources are available for download or use at no charge on
FCMAT’s website.
Fiscal Crisis and Management Assistance Team California Department of Education 2
About FCMAT
History
FCMAT was created by Assembly Bill (AB) 1200 in 1991. In 1997, AB 107 charged FCMAT with responsibility
for CSIS and its statewide data management work, and AB 1115 in 1999 codified CSIS’ mission.
AB 1200 created a statewide plan for county offices of education and school districts to work together
locally to improve fiscal procedures and accountability standards. AB 2756 (2004) gave FCMAT specific
responsibilities for districts that have received emergency state loans.
In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and
expanded FCMAT’s services to include these types of LEAs.
On September 17, 2018, AB 1840 was signed into law. This legislation changed how fiscally insolvent dis-
tricts are administered once an emergency appropriation has been made, shifting oversight responsibili-
ties from the state to the local county office of education to be more consistent with the principles of local
control, and giving FCMAT new responsibilities associated with the process.
Fiscal Crisis and Management Assistance Team California Department of Education 3
Introduction
Introduction
Background
On September 17, 2018, Assembly Bill (AB) 1840 (Chapter 426, Statutes of 2018) was signed, introducing a
significant change in the administration of insolvent school districts that receive state emergency appropri-
ations. Under this legislation, codified in Education Code (EC) 41326(l), the Fiscal Crisis and Management
Assistance Team (FCMAT) is tasked with reviewing the fiscal oversight performed by the county superinten-
dent of schools for any school district receiving an emergency apportionment. FCMAT must report its find-
ings to the Legislature and provide a copy of the oversight evaluation report to the Department of Finance,
the superintendent of public instruction, and the State Board of Education president or their designee. Each
report must include findings regarding the fiscal oversight actions that were or were not taken and may
contain recommendations for legislative measures to improve fiscal oversight of school districts.
On August 29, 2025, the State Controller’s Office issued the first apportionment of $8.5 million of an
emergency appropriation to the Plumas Unified School District under AB 121 (Chapter 8, Statutes of 2025).
Plumas is a single-district county, and the district and Plumas County Office of Education share many of the
same administration. The California Department of Education (CDE) is the agency responsible for providing
fiscal oversight. Statute does not contemplate a school district in a single-district county requiring an emer-
gency apportionment. Therefore, EC 41326(l) is not fully applicable to Plumas USD. Paragraph (3) of subdivi-
sion (e) of Section 98 of AB 121 provides the following:
(A) In accordance with subdivision (l) of Section 41326 of the Education Code, the FCMAT
shall review the fiscal oversight of the Plumas Unified School District by the Superintendent
of Public Instruction pursuant to subdivision (i) of Section 42127 and subdivision (g) of Section
42131. The FCMAT may consult with other fiscal experts, including other county superinten-
dents of schools and regional fiscal teams, in conducting this review.
(B) Within three months of the county superintendent of schools assuming control over
Plumas Unified School District, the FCMAT shall report its findings to the Legislature, consis-
tent with Section 9795 of the Government Code, and shall provide a copy of that report to
the Department of Finance, the Superintendent of Public Instruction, and the President of the
State Board of Education or their designee. This report shall include findings as to fiscal over-
sight actions that were or were not taken and may include recommendations as to an appro-
priate legislative response to improve fiscal oversight.
(C) In the year following the completion of the report required pursuant to subparagraph (B),
the FCMAT shall begin annual reviews of the effectiveness of the oversight of the Plumas
Unified School District by the Superintendent of Public Instruction.
This is the initial report on the CDE’s oversight of the district, as required. Following the initial FCMAT
report on the fiscal oversight performed by the CDE, FCMAT will conduct annual reviews until the school
district exits receivership. These reviews will assess the effectiveness of the CDE’s oversight and its
involvement with the school district, including during the period that led to the district’s declaration of
insolvency.
Fiscal Crisis and Management Assistance Team California Department of Education 4
Introduction
About this Study and Report
FCMAT entered into a study agreement with the CDE on August 4, 2025 to conduct both the initial and
annual evaluations required by EC 41326(l) and AB 121. A study team visited the CDE virtually on August 5,
2025 to conduct interviews, collect data, and review documents. After this virtual fieldwork, the study team
continued to analyze the gathered documents and data. This report summarizes the team’s activities and
actions related to the initial evaluation.
FCMAT’s reports focus on systems and processes that may need improvement. Those that may be func-
tioning well are generally not commented on in FCMAT’s reports. In writing its reports, FCMAT uses the
Associated Press Stylebook and its own short internal style guide, which emphasize plain language, capital-
ize relatively few terms, and strive for conciseness, clarity and simplicity.
Study Team
The team was composed of the following members:
John F. Von Flue Misty Key
Chief Analyst FCMAT Consultant
Sheldon Smith, Ed D Nicolas Schweizer
FCMAT Consultant FCMAT Consultant
John Lotze
FCMAT Technical Writer
Those members of this study team who are otherwise employed by a local educational agency were not
representing their respective employers but were working solely as independent contractors for FCMAT.
Each team member reviewed the draft report to confirm accuracy and achieve consensus on the analysis.
California Department of Education Oversight
Evaluation Tool
The Fiscal Crisis and Management Assistance Team (FCMAT) has developed the California Department of
Education Oversight Evaluation Tool for both initial and annual evaluations. This tool is designed to help
assess the effectiveness of the California Department of Education’s (CDE’s) fiscal oversight and support of
single-district county school districts that have received emergency apportionments.
This initial oversight evaluation tool comprises 37 questions and is intended to satisfy the requirements of
EC 41326(l) and AB 121. Its purpose is to review and assess the CDE’s fiscal oversight process by evaluat-
ing how effectively the CDE monitors the general fiscal health of the single-district county school districts
under its oversight, assesses the districts’ adherence to Education Code requirements, and communicates
with the districts about these matters.
The oversight evaluation tool identifies the CDE’s key oversight responsibilities in reviewing annual bud-
gets, interim reports and unaudited actuals. Each question is confined to a “Yes” or “No” response. To help
the CDE understand any “No” responses, narratives are provided that explain the reasoning behind the
response and outline the action(s) needed to achieve a “Yes” response.
Fiscal Crisis and Management Assistance Team California Department of Education 5
Introduction
The CDE’s oversight performance is evaluated using a risk protocol, whereby the number of “No”
responses within each oversight element determines the level of concern. The greater the number of “No”
responses, the higher the score, which indicates a lack of sufficient oversight. Information for the evaluation
is gathered through an initial document request and interviews with CDE staff.
Early identification of issues in school districts at risk of insolvency is crucial for restoring and maintaining
their fiscal health. Diligent oversight helps school districts better understand their financial objectives and
implement strategies to achieve a high level of fiscal efficiency and maintain long-term solvency.
Date of Fieldwork: August 5, 2025
Fiscal Crisis and Management Assistance Team California Department of Education 6
Summary
Summary
On April 28, 2025, the Plumas Unified School District (Plumas USD) governing board voluntarily requested
that the state provide an emergency advance apportionment. On June 27, 2025, the governor signed
Assembly Bill (AB) 121, placing the district under state receivership and approving an emergency appropria-
tion of up to $20 million.
The California Department of Education (CDE) provides fiscal oversight to all 58 California county offices
of education and to the districts of the seven single-district counties, as mandated by the original AB 1200
legislation signed into law in 1991 and outlined in California Education Code (EC) 1240(l)(1)(A), 1622, 42127(l)
and related sections. FCMAT assessed the CDE’s involvement with the district throughout the course of
their normal oversight responsibilities, up to and including the date of evaluation, and specifically during the
period leading up to the district’s declaration of insolvency. This assessment involved analyzing historical
and current documents prepared by CDE’s staff, as well as asking a series of questions related to the time
leading up to the insolvency. FCMAT also reviewed the CDE’s oversight practices and conducted interviews
with district staff and other key individuals involved in the oversight process.
To conduct this initial study, FCMAT used the tool developed in 2020 to conduct reviews of county super-
intendents of schools pursuant to the same Education Code that applies to Plumas USD and the CDE. The
initial evaluation tool evaluates the standards at four points in the oversight process, increasing the number
of points of compliance/noncompliance. This is different from the annual evaluation that will be performed
each year the emergency advance apportionment is outstanding. FCMAT also acknowledges that the CDE
provides oversight to all county offices of education and all single-district counties, but FCMAT’s samples to
inform this report were taken from only one district – Plumas USD. Only Plumas USD entered state receiver-
ship and triggered this review. CDE staff did not provide any information that would lead FCMAT to believe
the oversight process for Plumas was different from any other oversight activity for the other agencies the
CDE is responsible for overseeing.
The period of this review is a combination of 2023-24 and 2024-25. Logically, the review would be the most
recent year, 2024-25. However, the difficulties at Plumas USD were discovered mid-year, before the first
interim, second interim and estimated actuals were reviewed. Therefore, a review of only 2024-25 would
be misleading as it would underreport any oversight issues that prevented early detection of Plumas USD
‘s difficulties. Thus, a review of the CDE’s 2023-24 oversight process (before Plumas USD’s difficulties were
detected) would be a better indicator if deficiencies existed.
FCMAT’s findings indicate that the fiscal oversight actions taken by the CDE during the period reviewed
were based on reviews of district-submitted documents, without close connections or proximity to the
district’s financial system and staff. Unlike county offices of education, the CDE’s oversight is made chal-
lenging by its lack of close proximity to the district and the ease of awareness and relations that proximity
would offer. In addition, the CDE did not have access to the district’s fiscal system and relied solely on
information the district submitted in its state reports or otherwise shared. Without the ability to validate the
information provided, the CDE’s process is vulnerable to incomplete and incorrect information, and there-
fore, insufficient oversight.
FCMAT acknowledges that the CDE’s staff and operations are not the same as those of county superinten-
dents of schools. Staffing, training, funding, relationships with counties and districts, and proximity are all
different. CDE staff typically do not have local educational agency (LEA) experience or the understandings
and perspectives that it brings. Nevertheless, the expectations of the Legislature and the adopted stan-
dards and criteria for fiscal solvency remain consistent regardless of which local or state agency is respon-
sible for the oversight.
Fiscal Crisis and Management Assistance Team California Department of Education 7
Summary
The Plumas Unified School District experienced a multiyear deterioration of its unrestricted general fund,
resulting in structural deficit spending, cash shortfalls, and the complete exhaustion of available reserves.
In fiscal year 2021–22, the district reported a beginning balance of $843 as a due-to-liability from the
general fund due to the building fund at first Interim as identified in its annual financial audit. Throughout
the fiscal year, various entries added to the liability, and by the end of fiscal year 2021-22 the total liability
grew to $5,126,501, with $3,000,842 owed to the Building Fund and $2,125,659 owed to the County School
Facilities Fund.
Compounding the issue, leadership changes occurred near the same time, with a superintendent retiring at
the end of the 2021-22 school year and the chief business official resigning in November 2022. In addition,
in December 2022 the board approved a two-year compensation increase of 9% ongoing beginning July
1, 2022 and an additional 4% ongoing beginning July 1, 2023, and increased contributions to health and
welfare benefits for all staff.
During the 2022-23 fiscal year, the district’s Standardized Account Code Structure (SACS) Cash Form did
not show any activity in any months in the “Due to Other Funds” line of its interim reports, which indicated
to the CDE that interfund borrowing was not necessary. Additionally, district-submitted reports did not indi-
cate any interfund transfers or cash flow concerns involving the general fund for the fiscal year. The fiscal
year 2022-23 annual financial audit report was completed nine months late (August 2024) and was not
presented to the governing board until March 5, 2025, 14 months after the statutory deadline. This delayed
the CDE getting vital information for effective oversight. The fiscal year 2022-23 audit report indicated that
the $5,126,501 in “Due to Other Funds” remained, which indicated that the prior year’s interfund borrowings
were still not paid back to the appropriate funds, in violation of EC 42603.
In the 2023-24 fiscal year, the district projected its Local Control Funding Formula (LCFF) revenue as a
non-basic-aid district, resulting in an advance apportionment of $4.5 million. However, during the year, the
district transitioned back to basic-aid status and was required to return $3.1 million of the advance appor-
tionment. The district did not account for the return of these funds and overstated its LCFF revenue expec-
tation to its governing board and the CDE. In March and July of 2024, the district submitted its 2023-24
second interim financial report and its 2024–25 adopted budget to the CDE, both of which projected fiscal
solvency through the current and two subsequent years. This overstatement was not discovered until the
district prepared its fiscal year 2023-24 unaudited actuals in September 2024, revealing a negative unre-
stricted ending fund balance as of June 30, 2024. The negative ending balance translated into a negative
beginning fund balance for the 2024-25 fiscal year, which was reflected in the 2024-25 first interim financial
report. In response, the district self-certified as negative in December 2024.
During fiscal year 2024-25, leadership changed again as the superintendent was placed on administrative
leave and then resigned in October 2024, and an interim superintendent was hired in November 2024.
Over the course of fiscal year 2024-25, further compensation increases of 2.5% were approved for all
county office and district staff, retroactive to July 1, 2024.
In December 2024, the district notified the CDE that it would be submitting its first Interim report with a
negative certification. The CDE notified the Fiscal Crisis and Management Assistance Team (FCMAT) of this
and requested emergency assistance for the district. The CDE also immediately appointed a fiscal advisor
to provide intervention and assistance to the district.
The district again self-certified as negative at 2024-25 second interim, with a negative unrestricted ending
fund balance, no reserve for economic uncertainties, and no remaining cash flexibility. The district received
support from a CDE-appointed fiscal advisor and FCMAT to assess solvency risks and identify recovery
options. The situation remained critical, with continued deficit spending. On June 27, 2025, the governor
Fiscal Crisis and Management Assistance Team California Department of Education 8
Summary
signed AB 121 (omnibus budget trailer bill for education) to provide the district with an emergency advance
appropriation of up to $20 million.
It remains unclear whether the district’s leaders did not have the experience and capacity to understand
the situation or whether they intentionally covered up the situation to give a false appearance of finan-
cial stability. It is likely a combination of the two. Because the CDE did not have direct access to the fiscal
system, it relied solely on budget, interim, collective bargaining disclosures, and audit reports to ascertain
the district’s fiscal status. Because of its lack of proximity, the CDE was at a disadvantage in its ability to
assess staff experience and capacity at the district. Poor leadership and unjustifiably late audit reports also
contributed to the lack of awareness of the district’s fiscal status.
In reviewing the CDE’s oversight actions, it is evident that the following indicators of risk or potential fiscal
insolvency went unmonitored and/or undetected:
• Audit – failure to complete audit within statutory timelines.
• Insufficient Budget Monitoring – actual revenues and expenditures not consistent with
budget; inadequate explanations of criteria and standards variances; failure to regularly
reconcile balance sheet accounts.
• Inadequate Cash Management – failure to reconcile cash monthly; failure to comply with
interfund borrowing requirements.
• Mismanaged Collective Bargaining Agreements – failure to adequately quantify the fiscal
impact of collective bargaining agreements; compensation increases above funded COLA.
• Continued Deficit Spending – deficit spending in recent fiscal years.
• Inattention to Enrollment and Attendance – failure to monitor and analyze enrollment and
average daily attendance (ADA).
• Inadequate Fund Balance and Reserve for Economic Uncertainty - failure to accurately
estimate the ending fund balance; failure to maintain minimum reserve; unstable or
decreasing projected unrestricted fund balance.
• Nonintegrated Information Systems and Data Management – financial systems not
integrated.
• Ineffective Internal Controls – failure to post and reconcile beginning balances with the
prior year ending balances.
• Weakness in Leadership and Stability – turnover of superintendent and CBO positions.
• Inadequate Multiyear Projections – multiyear projections not in accordance with reason-
able projection year assumptions; failure to explain trend analysis; failure to consider multi-
year projections when making financial decisions.
Although the CDE maintains analytical tools to evaluate district fiscal report submissions, interviews con-
firmed that an increased level of engagement and ongoing communication would have helped identify
the weaknesses in the district’s systems and processes. The CDE has also identified areas that can be
improved in its own fiscal oversight processes and its efforts to ensure that fiscal distress is identified
sooner. Many of these improvements, which included CDE staff steps for fiscal report review and informa-
tion validation, have been incorporated into a new budget review checklist.
Fiscal Crisis and Management Assistance Team California Department of Education 9
Summary
Suggested Next Steps to Improve Oversight
It is possible that the CDE and other agencies may want to consider alternative approaches to providing
front line oversight activities, such as a specialty group within the CDE, a regional oversight structure
specifically for single-district counties, and/or other approaches. This will allow specialization and poten-
tially attract staff with LEA experience. This supports the notion that there is both a science and an art to
Assembly Bill 1200 fiscal oversight. The technical aspect is the science and is the simpler of the two. The
art is built upon relationships, proximity, and a deeper understanding of the unique nature of each district.
An alternative structure may also overcome both the natural resistance to state oversight and any reluc-
tance to offer full transparency. Single-district counties are different than multidistrict counties, and they
fulfill what are typically district responsibilities, including direct general education instruction. They are also
more likely than a typical county office of education to get into fiscal distress and potentially become insol-
vent, as is the case at Plumas USD.
As this report notes, immediately after the context and information about Plumas USD was understood, the
CDE took steps to enhance its oversight checklist for budget adoption, interim reports, and estimated actu-
als. When used consistently, the new checklist will greatly improve the CDE’s oversight process. An evalu-
ation based on the CDE’s 2025-26 oversight activity will occur around September of 2026. There is every
indication that it will reflect improved conditions based on the actions CDE has already taken.
One major difference between county superintendents of schools’ oversight process and the CDE’s pro-
cess is that county superintendents have access to districts’ financial systems and can view the details
of transactions. County offices of education and single-district counties operate like fiscally independent
districts, but without the same required checks and balances as fiscally independent districts. Because of
this, the CDE is not the agency processing commercial or payroll warrant transactions for a district, nor is
it the agency hosting the local financial system. Therefore, daily transactions and financial details are not
visible or available to the CDE; it sees only the data reported in the Standardized Account Code Structure
Web System. It has no way to independently verify the data or review sample transactions. The Legislature
should give the CDE the authority to have read-only access to all financial systems used by local educa-
tional agencies that are subject to CDE oversight.
Although it would be separate from FCMAT’s role in conducting this initial evaluation and the annual eval-
uations to come, FCMAT is willing to provide any training or other assistance to our CDE partners that will
enhance their oversight role. This includes training in oversight and how to read financial system reports
Fiscal Crisis and Management Assistance Team California Department of Education 10
Findings
Findings
This section focuses on FCMAT’s review of the California Department of Education’s (CDE’s) fiscal over-
sight actions. Each assessed area is listed below. A “Yes” response indicates that FCMAT found sufficient
evidence to indicate that appropriate fiscal oversight actions were taken. A “No” response indicates either
insufficient documentation or a lack of attention to that particular responsibility. If a deficiency in an area
is material, it is noted in the accompanying narrative. For any “No” responses, an explanation is provided,
outlining the action(s) required to achieve a “Yes.”
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
1 Did the CDE receive and retain budget and interim report certifi-
cation forms from the district, complete with original signatures?
In interviews, CDE staff stated that certification forms are
routinely collected at each submission. A review of certifica- Yes Yes Yes Yes
tion forms and CDE tracking spreadsheets indicated that the
signed certifications are routinely received for the budget
and interim reports.
2 Did the CDE review the status of all the district’s import, export,
general ledger, and supplemental SACS-Web technical review
checks?
Per interviews with CDE staff, the SACS technical review
checks are performed as part of the CDE acceptance pro-
cess. District submissions reviewed by FCMAT were com-
plete, with no fatal errors.
The CDE provided a document titled “2025-26 Budget Yes Yes Yes Yes
Review Checklist” that was recently developed, which
interviewees stated would be used to organize reviews
beginning July 1, 2025. The checklist contains 98 budget
items and activities to review and confirm, including verify-
ing that the submission had no fatal “F” exceptions and that
allowable exceptions had reasonable explanations. Using
this checklist and accompanying manual will help the CDE
continue to meet this standard.
Fiscal Crisis and Management Assistance Team California Department of Education 11
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
3 Did the CDE evaluate the reasonableness of the explanations
for the allowable exceptions noted in the district’s SACS-Web
technical review check?
Technical review exceptions for the budget, first and second
interim reports identified several nonfatal warnings. District
provided explanations accompanied all exceptions.
Interviews revealed that CDE staff identify and discuss the
district explanations for any exceptions in the technical
review check (TRC); however, no evidence was found that
the CDE evaluates the exceptions or the explanations. No
questions or concerns from the CDE review were found No No No No
documented or communicated to the district.
In interviews, CDE staff stated the 2025-26 Budget Review
Checklist would be used to organize reviews beginning
July 1, 2025 and should support meeting this standard. This
checklist contains 98 budget items and activities to review
and confirm, including verifying that the submission had
no fatal “F” exceptions and that allowable exceptions had
explanations. In addition, the CDE will need to establish
a standard of reasonableness and acceptance for district
explanations.
4 Did the CDE verify whether the district had any fatal “F” excep-
tions in the SACS-Web technical review process?
According to interviews, the CDE’s stated process is to verify
Yes Yes Yes Yes
that there are no fatal errors in the district’s technical review
and to note any exceptions. A review of the district’s SACS
forms and data files submitted found no fatal errors.
5 Did the CDE review and validate transfers made from the
district’s restricted funds (e.g., building fund, bond interest and
redemption fund, self-insurance fund)?
The CDE’s district budget and interim review tool (DBIRT)
has review tabs for budget and first and second interim fund
summary, on which CDE staff record transfers in and out
of each fund as submitted by the district at each reporting
period. However, there is no active and timely review of
transfers.
Until recently, the CDE did not have access to the district’s
No No No No
financial system to review transfers. The only indication that
the CDE reviews transfers was found in the fiscal year 2025-
26 budget review correspondence to the district, which calls
out the timing of repayment of 2024-25 transfers for funds 17
and 35.
The CDE should review all budgeted and enacted transfers
reported by the district and ensure their appropriateness,
including whether they are temporary and need to be repaid
or permanent. Further, the CDE’s records and correspon-
dence with the district should document this review.
Fiscal Crisis and Management Assistance Team California Department of Education 12
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
6 Did the CDE review Form A and determine whether the district’s
prior year second principal apportionment and annual average
daily attendance (ADA) figures matched its actual attendance
report?
There is no evidence that Form A (or Form AI) is reviewed for
validity or whether district enrollment and ADA is compared
to other reporting periods.
No No No No
The recently-developed 2025-26 Budget Review Checklist
references reviewing ADA data to validate figures reported
on the second principal apportionment and annual average
daily attendance budgeted match, determine the reason
for any significant changes in ADA, and determine whether
projections are reasonable. This process will help the CDE
meet this standard.
7 Did the CDE investigate and determine the reason(s) for any
significant change in ADA since the previous reporting period
and discuss this change with the district?
No documentation was found to indicate that an evaluation
of ADA data or trends occurs in the CDE’s review process.
The CDE notes in the DBIRT whether ADA is ”met” or “not
met” in the district’s reported criteria and standards, and the
ADA as reported in the district audit..
No No No N/A
The recently-developed 2025-26 Budget Review Checklist,
implemented as of July 1, 2025, references reviewing the
ADA reported in the current submission to validate whether
the figures align with those reported on the prior year sec-
ond apportionment and the annual average daily attendance
reports, determine the reason for any significant changes
in ADA, and determine whether projections are reasonable.
This process will help the CDE meet this standard.
8 Did the CDE verify whether the district’s enrollment and ADA
projections are reasonable? The industry standard is to review
enrollment trends over at least the last three years.
No documentation provided indicated that enrollment and/
or ADA projections are evaluated for reasonableness during
the CDE’s review process. The enrollment and ADA status
in the criteria and standards for each reporting period are
recorded in the DBIRT as “met” or “not met,” with no further No No No N/A
comment.
The recently-developed 2025-26 Budget Review Checklist
implemented as of July 1, 2025 references reviewing CAL-
PADS and ADA historical data to assess the reasonableness
of enrollment and ADA projections. This process, along with
establishing a standard for reasonableness, will help the
CDE meet this standard.
Fiscal Crisis and Management Assistance Team California Department of Education 13
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
9 Did the CDE evaluate the reasonableness of the district’s expla-
nations in the Criteria and Standards Review form (Form 01CS)?
The CDE documents the SACS criteria and standards
provided by the district for each reporting period and notes
whether the standard is met or not met. The district-provided
explanation for each “not met” is also recorded. Interviews
revealed that CDE staff identify and discuss concerns re-
garding explanations identified in each submission; however,
no documented evidence was found to show that the CDE No No No N/A
evaluates for reasonableness or communicates any identi-
fied concerns back to the district.
The recently-developed 2025-26 Budget Review Checklist
identifies enhanced checks and review activities for the
criteria and standards in future budget and interim reports.
This process, including evaluating explanations and commu-
nicating concerns to the district, will help the CDE meet this
standard.
10 Did the CDE evaluate the reasonableness of the multiyear com-
mitments in Form 01CS by comparing them with the information
in the district’s most recent audit report?
Evidence was provided that the CDE reviewed district
audits, and applied audit debt information and findings to
the district’s most recent budget submission. The CDE also
corresponds with the district regarding audit findings, their
impact and resolution. No No No N/A
However, no evidence was found that the CDE reviewed
multiyear commitments and made judgments about the rea-
sonableness of those commitments.
When reviewing a district’s multiyear commitments, the
CDE should evaluate them based on historical trends and
forward-looking assumptions, and confirm alignment with the
district’s annual audit.
11 Did the CDE evaluate the reasonableness of retiree health and
welfare benefit liabilities by comparing them with the informa-
tion in the district’s most recent audit report?
The CDE tracks and documents the district-reported retiree
health and welfare liability in its DBIRT at each reporting
period. The DBIRT provides for a comparison of liabilities
between audit and current reporting period to identify
differences. However, although differences are evident, no
No No No N/A
evidence of evaluation was provided and no CDE comments
or concerns were noted.
To meet this standard, the CDE should continue to identify
differences between the district’s audit report and its fiscal
reports. Any differences should be understood and evaluat-
ed for reasonableness. The CDE should request additional
information from the district to clarify, and should communi-
cate any concerns.
Fiscal Crisis and Management Assistance Team California Department of Education 14
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
12 Did the CDE verify the accuracy of any salary settlements or
negotiations by comparing them to the bargaining agreements
included in the district’s Form 01CS and any Public Disclosure of
Collective Bargaining Agreement?
For the 2024-25 agreements, the CDE provided documents
and evidence of Public Disclosure of Collective Bargaining
Agreement (AB 1200 disclosure) receipt and impact review,
complete with a reviewer’s notes in the DBIRT. However, this
process does not appear to be completed for settlements in
preceding years. No No No N/A
In all settlements reviewed, the CDE took the information
provided by the district and then applied the fiscal impact of
the settlement. No evidence was provided to indicate that
the CDE verified the accuracy of the data received from the
district.
An extensive review of all collectively-bargained settlement
public disclosures, including the verification of the district
calculations and the fiscal impact of the settlement, needs to
occur and be documented to meet this standard.
13 If the district received a qualified or negative certification, did
the CDE review the district’s Public Disclosure of Collective Bar-
gaining Agreement and provide comment on the agreement’s
viability and affordability within the statutorily required 10-day
period?
The CDE provided documents and evidence of the 2024-
N/A Yes Yes N/A
25 collectively-bargained agreement disclosure receipt and
review, complete with a reviewer’s notes and analyses in the
DBIRT.
In addition, the CDE provided timely correspondence to
the district regarding concerns over the affordability of the
agreements.
14 Did the CDE compare the district’s budgeted revenues and ex-
penditures to estimated actuals for the adopted budget period,
historical trend data for both the adopted budget and interim
periods, and actuals to date for the interim periods?
The CDE DBIRT includes a comparison and analysis of dis-
Yes Yes Yes N/A
trict budgeted and actual revenues and expenditures at each
budget and interim reporting period. Also included in the
DBIRT is a comparison of historical and projected changes in
revenues and expenditures, expenditure category ratios to
total budgeted expenditures, and expenditure trends.
Fiscal Crisis and Management Assistance Team California Department of Education 15
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
15 Did the CDE review the “% of difference” column for reason-
ableness in the following: adopted budget (Form 01 “% Diff”
column and Form MYP “% change” columns B and D), interim
report (Form 01 “% Diff” column F and Form MYP “% change”
columns B and D), and unaudited actuals report (Form 01 “%
Diff” column)?
The CDE’s DBIRT tool provides for a thorough comparison
and analysis of the budget and interim reporting period data
No No No No
that highlights anomalies and variances. Per interviews, the
CDE staff meet to discuss concerns identified in the DBIRT.
However, CDE documents provided for this review lack
evidence of CDE staff review and documentation of the rea-
sonableness of the reported data.
To meet this standard, the CDE should incorporate the eval-
uation of reasonableness into its comparisons and analyses
of data.
16 Did the CDE verify whether the district’s reserve calculation
meets the applicable percentage of reserve requirement in
object 9789 (Reserve for Economic Uncertainties)?
The CDE-maintained DBIRT provides a comparison of the
district’s reserves for budget and interim reporting periods.
Yes Yes Yes No
However, there was a lack of documented evidence of re-
view of the district’s unaudited actuals.
The CDE should implement a review of the district’s unau-
dited actuals as it does for the budget and interim periods in
the DBIRT.
17 Did the CDE verify whether object 8011 (LCFF State Aid – Cur-
rent Year) aligns with the district’s LCFF Calculator for the
current year and in the multiyear projection for both the budget
and interim reports?
There was a lack of documented evidence of the CDE’s
validation that object 8011 (LCFF State Aid – Current Year)
aligned with the district’s LCFF calculator for budget and
interim reporting periods. Interviewees shared that this
process of cross-checking LCFF amounts was happening in No No No N/A
the review of the LCAP and budget. The DBIRT used by the
CDE fiscal oversight review team did not have a prompt or
section to confirm whether LCFF amounts matched those in
the LCFF calculator or any other source document.
The 2025-26 Budget Review Checklist will help the CDE
complete this activity by verifying that budgeted object 8011
agrees with the LCFF calculator and is in reasonable align-
ment with the multiyear projections.
Fiscal Crisis and Management Assistance Team California Department of Education 16
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
18 Did the CDE verify whether local tax revenues align with the
district’s most recent local revenue submission in the Principal
Apportionment Data Collection Software?
No evidence was provided to verify local tax revenue
alignment. In interviews, staff stated they were not verifying
whether local tax revenues aligned with the district’s most re-
cent property tax revenue report submission. Staff indicated
that the local property tax revenues report is submitted to a No No No No
different group in the same department at the CDE, and the
DBIRT did not include a section to cross-check the property
tax revenue against the latest budget projection.
The 2025-26 Budget Review Checklist will help the CDE
complete this activity by reviewing tax revenues budget-
ed with the prior year principal apportionment P-2 funding
exhibit.
19 Did the CDE evaluate the reasonableness of the district’s
assumptions and budgeted revenues by comparing them with
information from the latest state budget, the School Services of
California, Inc. dartboard, and the LCFF Calculator?
There was a lack of documented evidence to validate
cross-checking of the district’s assumptions and budgeted
revenues against information from other sources, including the
state budget, School Services of California, Inc. dartboard, and
the LCFF calculator. Interviewees indicated that the CDE team
participates in workshops and conferences to obtain updated in-
formation and details related to the latest state budget assump-
tions and revenue projections. However, the DBIRT does not
have a designated section for cross-checking revenue assump-
tions against other published state budget projections. Further, No No No N/A
there is no established process for reviewing district assump-
tions and budget projections for reasonableness.
The 2025-26 Budget Review Checklist contains the follow-
ing action language, which will support this standard:
Check if the Local Education Agency (LEA) has
reasonable assumptions and budgeted revenues
by comparing them to the latest state budget, the
School Services of California, Inc. dartboard, and
the LCFF Calculator. Ask for their assumptions
if they haven’t provided any. Assess the LEA’s
assumptions about LCFF funding, Average Daily At-
tendance (ADA) projections, and see if they match
CALPADS or historical data.
Fiscal Crisis and Management Assistance Team California Department of Education 17
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
20 Did the CDE evaluate the reasonableness of the district’s sala-
ries and benefits, including any increases or decreases due to
negotiation settlements, in both the current year budget and the
multiyear projection? Is the budget consistent with the district’s
assumptions and Form 01CS?
The CDE-maintained DBIRT contains fields for comparisons
and analyses of the district’s salary and benefit budget and
expenditures, including the impact of negotiated settle-
ments. The DBIRT is to be completed for every budget and
interim reporting period and includes projected expenses No No No N/A
versus budget and period-over-period comparisons.
However, this area of the DBIRT is not consistently complet-
ed, and there is no documented evaluation of salaries and
benefits budgets and variances identified on the DBIRT.
The CDE staff should complete the DBIRT sections for salary
and benefits and collective bargaining analysis. In addition,
the CDE staff should review the effects of collective bar-
gaining and budgeting assumptions and evaluate them for
reasonableness.
21 Did the CDE identify and evaluate the reasonableness of the
increases or decreases in the district’s other financing sources
and uses?
The CDE-maintained DBIRT tracks and compares the district
reported other financing sources and uses for each reporting
period. CDE staff are to note any significant variances; how- No No Yes N/A
ever, there is a lack of documentation of review and evalua-
tion of this information.
For future compliance, the CDE needs to identify changes in
the district’s other financing sources and uses and evaluate
whether they are reasonable.
22 Did the CDE verify whether the base year totals in the district’s
multiyear projection match the General Fund budget totals on
the district’s Form 01?
Yes Yes Yes N/A
The CDE-maintained DBIRT records, compares and verifies
whether the multiyear projection base amounts match the
current period data and identifies any variances.
23 If line B10 on the multiyear projection was used, did the CDE
verify whether the district included detailed assumptions or
information to explain the adjustment?
No B10 adjustments were used on any of the 2024-25 N/A N/A N/A N/A
budget or interim multiyear projections. However, the DBIRT
contains space to report and comment on any such adjust-
ments should they exist.
Fiscal Crisis and Management Assistance Team California Department of Education 18
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
24 Did the CDE evaluate the reasonableness of the district’s pro-
jections for supplies, services, capital outlay and other expendi-
tures (e.g., energy costs, one-time expenses)?
The CDE uses the DBIRT to track and compare the district’s
budget and actual expenditures for each reporting period
as well as for the multiyear projections. Trends and varianc-
No No No N/A
es are identified, and presumably clarification is requested
from the district. However, there is no evidence that the CDE
validates any variances and evaluates the projections for
reasonableness.
The CDE needs to establish a validation of data and evalua-
tion of reasonableness for district expenditure projections.
25 Did the CDE verify whether the district’s prior year ending
balances were accurately carried forward as beginning balances
(not applicable for budget period)?
The CDE uses the DBIRT to compare the prior year end-
ing balances with current year beginning balances at first
interim. The CDE uses the district’s annual audit report to
compare ending balances with beginning balances.
The DBIRT shows a significant difference between the 2023-
24 audit report ending fund balance and the 2024-25 first
N/A Yes No No
interim beginning fund balance for the general fund. Howev-
er, there are no comments in the DBIRT noting differences.
The CDE commented that the audit report identified material
weaknesses and deficiencies in the financial statements and
detailed the multiple audit findings.
To support future compliance, the 2025-26 Budget Review
Checklist includes a place to document the verification of
whether ending balances are carried forward to beginning
balances at each reporting period.
26 Did the CDE verify whether the district projects maintaining the
minimum reserve for economic uncertainties, in accordance
with the guidelines established in the State Standards and
Criteria for Fiscal Solvency, for the current year and the two
subsequent years? Yes Yes Yes N/A
The CDE-maintained DBIRT includes extensive analysis
and records staff members’ notes on the district’s reported
reserves, including its ability to meet its minimum reserve
requirement in the current and two subsequent years.
27 Did the CDE evaluate the reasonableness of the district’s be-
ginning cash balance for July 1 on the cash flow projection and
whether it was accurately carried forward from the prior year?
The CDE’s DBIRT includes cash form review actions to
validate beginning cash balance; however, no evidence was
N/A No No No
provided to verify the validations are completed.
To support future compliance, the CDE’s 2025-26 Budget
Review Checklist includes a place to document the validation
of beginning cash balances, which, if used, would support
meeting this standard.
Fiscal Crisis and Management Assistance Team California Department of Education 19
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
28 Does the CDE monitor the district’s cash flow on at least a
monthly basis and communicate any concerns about the cash
balance to the district?
The CDE has not historically had access to the financial
systems of any of the local education agencies (LEAs) it
monitors for fiscal health (or their respective county auditor/
controller), and it has not actively monitored cash balances.
The CDE’s DBIRT instructs CDE staff to validate district-re-
No No No N/A
ported beginning cash balances and check that projected
cash balances are not negative for any month.
Recently, the CDE has obtained access to the Plumas Unified
School District’s financial system. This access, along with
actions in the 2025-26 Budget Review Checklist, will help
the CDE monitor monthly cash flow going forward. Inde-
pendently verifying cash balances with the county treasurer
or county auditor/controller is also important.
29 Did the CDE identify any tax revenue anticipation notes issued
in the budget year, along with their repayment schedule? If so,
did the CDE verify whether the receipts and payments were
included in the cash flow worksheet and recorded in the general
ledger under object 9640 (Current Loans)?
The district has not issued any tax revenue anticipation
notes (TRANs) in the past four fiscal years.
The CDE’s DBIRT includes a tab to analyze and comment on N/A N/A N/A N/A
liabilities, but it is not clear the CDE has a process for deter-
mining whether TRANs receipts and payments are included
in the district’s cash flow and general ledger.
The 2025-26 Budget Review Checklist includes reporting of
TRANs activity and documents the monitoring of TRANs. This
reporting and documentation will help the CDE comply with
this standard.
Fiscal Crisis and Management Assistance Team California Department of Education 20
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
30 Did the CDE monitor or identify any temporary borrowing
between funds, verify the use of appropriate object codes,
determine whether due to/due from amounts were cleared,
and confirm the district’s compliance with applicable Education
Code requirements regarding limits and timelines?
The CDE’s DBIRT has review tabs for budget and for first and
second interim fund summary, on which CDE staff record
district-reported transfers in and out of each fund, whether
they are temporary (loans) or permanent. This recording is
only completed if the district reports interfund transfers in a
budget or interim reporting period. The CDE has not histori-
cally had access to the district’s financial system to check for
or verify interfund activity.
In CDE review documents and correspondence, references
to interfund activities were found only twice: for the 2024- No No No No
25 first interim, the CDE reviewers documented that there
were no interfund transfers budgeted; and subsequently, in
the CDE’s 2025-26 budget review correspondence with the
district, the need for the 2024-25 fiscal year temporary loan
repayments to funds 17 and 35 was called out.
The CDE should review all budgeted and enacted transfers
and determine their appropriateness, including whether they
are temporary (loans) or permanent. In addition, the CDE
should verify fund activities and balances monthly to ensure
interfund borrowing and transfers are known. The CDE’s re-
cords and correspondence with the district should document
this review. To support compliance with this standard, the
2025-26 Budget Review Checklist includes a place to docu-
ment the monitoring of transfers between funds.
31 Did the CDE verify whether the district reconciles prior year
accruals, suspense accounts, and general ledger/balance sheet
transactions at each reporting period?
The CDE does not verify whether the district reconciles its
accounts properly and in a timely manner. The CDE has not
historically had access to the financial systems of any of the
LEAs for which it conducts fiscal monitoring, limiting its ability No No No No
to verify whether the LEA reconciles accounts in a timely
manner.
Recently, the CDE has obtained access to the Plumas Unified
School District’s financial system and developed the 2025-
26 Budget Review Checklist to include and document its
verification of the district’s account reconciliations.
32 Did the CDE verify whether the district complies with main-
tenance of effort requirements for the applicable reporting
periods?
FCMAT found no evidence to indicate that the CDE monitors
N/A N/A N/A No
the district’s compliance with maintenance of effort require-
ments.
The CDE should include a review of maintenance of effort
requirements at each reporting period.
Fiscal Crisis and Management Assistance Team California Department of Education 21
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
Did the CDE verify whether the district complies with current
expense of education requirements for the applicable reporting
periods?
FCMAT found no evidence that the CDE monitors compli-
ance with current expense of education requirements. The
33 N/A N/A N/A No
CDE records audit findings, including noncompliance with
the current expense of education, at actuals (SACS form
CEA).
The CDE should include a review of compliance as reported
on SACS form CEA at unaudited actuals reporting.
34 If the district is deficit spending, did the CDE note the levels of
deficit spending and communicate their concerns to the district
governing board through the budget and/or interim report
letters?
The CDE’s DBIRT includes extensive analysis and notes on
the district’s revenues and expenditures, including any deficit
spending.
FCMAT’s review of CDE correspondence to the district at
budget and interim periods from fiscal year 2021-22 through
2024-25 budget found no communication or concern re- No No No N/A
garding deficit spending, though the DBIRTs identified such.
The CDE’s 2024-25 first interim report letter was the first to
identify the district’s level of deficit spending.
The CDE should continue using the DBIRT and use the
2025-26 Budget Review Checklist to identify and track
whether the district is deficit spending. In addition, the CDE
should routinely note the levels of deficit spending and any
concerns in its correspondence at each review period.
35 If the district has contingent liabilities, did the CDE evaluate the
district’s ability to manage debt service or eliminate the liability?
Did the CDE assess impact of these liabilities on the district’s
ending fund balance?
The CDE’s DBIRT includes fields in which to analyze and
comment on liabilities. The DBIRT contains comments that
the district has not consistently budgeted the actuarially-de-
termined contribution toward its OPEB liability, but it does
not make clear how this or the district’s other liabilities may No No No No
impact its ending fund balance. No other liabilities are noted.
To support compliance, the 2025-26 Budget Review
Checklist actions include a review of liabilities and a place
to record the CDE’s evaluation of the impact of a district’s
liabilities on its fund balance. The DBIRT should contain this
information as well. In addition, correspondence with the
district should include the CDE’s assessment of the impact of
liabilities.
Fiscal Crisis and Management Assistance Team California Department of Education 22
Findings
At
At
At Budget At First Second
No. Question Unaudited
Period Interim Interim
Actuals
Period Period
36 If the CDE received disclosures of non-voter-approved debt
from the district, did the CDE respond within the statutory time-
line?
There is no indication that district has submitted any non-vot-
er-approved debt disclosures. However, annual audits report
debt, including $3.57 million in certificates of participation
for facility improvements in 2018, $4.47 million in financing
bonds for a solar photovoltaic system in 2022, $72,495 in
equipment financing in 2024, and $1.81 million in financ- N/A N/A N/A N/A
ing bonds for energy conservation improvements in 2021.
However, no documentation was provided indicating district
disclosures or CDE review.
The CDE’s 2025-26 Budget Review Checklist actions include
a review and statutory response to non-voter-approved debt
and will support the CDE’s compliance with this standard.
The CDE should reconcile debt reported in a timely annual
audit with their Budget Review Checklist.
37 Is the CDE monitoring and facilitating the training of district
administrators who have budget authority and financial man-
agement responsibilities?
The CDE does not have processes for or documentation
indicating that it facilitates the training of administrators who
have financial management responsibilities.
According to interviewees, in the future the CDE’s 2025-26 No No No No
Budget Review Checklist will document whether district ad-
ministrators receive guidance on budget development, SACS
reporting, and multiyear projections, and it will maintain a
record of fiscal training provided. This will help the CDE com-
ply with this standard in the future.
Total “No” Responses 83
Scale
0 - 27, favorable oversight performance
28 – 54, marginal oversight performance
55+, poor oversight performance
Fiscal Crisis and Management Assistance Team California Department of Education 23
Conclusion
Conclusion
The California Department of Education (CDE) conducted a fiscal oversight process that extended trust
to the district and relied on data submitted. They did not cross-verify the data using multiple sources of
data to review and validate it, and it is acknowledged that CDE’s capacity to do so is more limited than
that of a county superintendent’s oversight process. FCMAT’s evaluation of this oversight using the
California Department of Education Oversight Evaluation Tool shows opportunities for enhancement and
improvement.
Interviews and document review found that the CDE’s fiscal services oversight processes, procedures and
culture differ from those of a county office of education in overseeing its school districts, even though the
statutorily required oversight is the same. This results in multiple disconnects in the CDE process for fiscal
report review and oversight. Interviews revealed that staff assume that LEAs use correct budgeting prac-
tices, document actions correctly, and base projections on valid assumptions. CDE staff stated that their
inquiries to LEAs typically result in resistance, likely due to the lack of established relationships.
The CDE’s tools for oversight continued to evolve over the past several years with its DBIRT and its
newly-developed Budget Review Checklist, which will further support its oversight activities. However,
to be successful, the CDE should not only improve its systems for validating information at each report-
ing period, but also improve its processes for inquiry and keeping informed between reporting periods.
Recommendations begin with establishing direct access to financial systems (as they have recently done
with Plumas Unified School District), regularly reviewing board meetings, and establishing more regular and
routine check-ins with the county offices of education and school districts they oversee.
FCMAT will continue to perform an annual review to assess the effectiveness of the CDE’s oversight of the
district in accordance with Education Code 41326(l) and AB 121.
Fiscal Crisis and Management Assistance Team California Department of Education 24
Appendix
Appendix
Study Agreement
Fiscal Crisis and Management Assistance Team California Department of Education 25
Appendix
FISCAL CRISIS & MANAGEMENT ASSISTANCE TEAM
STUDY AGREEMENT
FOR CDE OVERSIGHT EVALUATION
This study agreement, hereinafter referred to as Agreement, is made and entered into by and
between the Fiscal Crisis and Management Assistance Team, hereinafter referred to as the Team
or FCMAT, and the California Department of Education, hereinafter referred to as the Client;
collectively, FCMAT and Client are hereinafter referred to as the Parties. This Agreement shall
become effective from the date of execution hereof by FCMAT.
1. BASIS OF AGREEMENT
FCMAT provides a variety of services to local education agencies (LEAs) as authorized by
Education Code (EC) 42127.8(d) and 84041.In accordance with the provisions of Section 98
of Assembly Bill 121 (Chapter 8 / 2025), FCMAT will study the Clients fiscal oversight
specific to the Plumas Unified School District receiving an emergency apportionment.
FCMAT is required to report its findings to the Legislature and to provide a copy of the
report to the Department of Finance, the superintendent of public instruction, and the
president of the State Board of Education.
FCMAT will assign professionals to conduct the study. The professionals will include
FCMAT staff and may include professionals from county offices of education, school
districts, charter schools, community colleges, other public agencies or private contractors.
All professionals assigned shall work under the direction of FCMAT. All work shall be
performed in accordance with the terms and conditions of this Agreement.
2. SCOPE OF THE WORK
A. Scope and Objectives of the Study
Prepare an initial analysis of the state superintendent of public instructions fiscal
oversight provided to the Plumas Unified School District using FCMATs County
Superintendent of Schools Evaluation Tool, and make recommendations for
improvement, if any.
B. Services and Products to be Provided
1. Orientation Meeting
The Team will conduct an orientation session at the Clients location to brief the
Clients management and supervisory personnel on the Teams procedures and the
purpose and schedule of the study. This orientation meeting is normally held at the
beginning of fieldwork for the study.
2. Fieldwork
The Team will conduct fieldwork at the Clients office and/or school site(s), or other
locations as needed. Limited fieldwork may also be conducted remotely via telephone
V12192023
Fiscal Crisis and Management Assistance Team California Department of Education 26
Appendix
or videoconferencing services, in addition to Public Safety Considerations outlined in
Section 13 below.
3. Exit Meeting
The Team will hold an exit meeting at the conclusion of the fieldwork to inform the
Client of the status of the study. The exit meeting will include a review of the scope
of work, outstanding items, including documents, data and interviews not yet received
or held, and the estimated timeline for a draft report. The meeting will not
memorialize details regarding findings because the Teams conclusions may change
after a complete analysis is finished. Exceptions to this will be findings of immediate
health and safety concerns for students or staff, and other time-sensitive items that
include the potential for risk or exposure to loss.
4. Exit Letter
Approximately five business days after the exit meeting, the Team will issue an exit
letter briefly memorializing the topics discussed in the exit meeting.
5. Draft Report
An electronic copy of a preliminary draft report will be delivered to the Clients point
of contact identified below for review and comment.
6. Final Report
An electronic copy of the final report will be delivered to the Clients point of contact
and to the Clients county superintendent of schools following completion of the
study. FCMATs work products are public and all final reports are published on the
FCMAT website.
3. PROJECT PERSONNEL
The personnel assigned to the study will be led by a FCMAT staff person (job lead) and will
include at least one other professional. FCMAT will notify the Client of the assigned
personnel when the fully executed copy of this Agreement is returned to the Client.
FCMAT will communicate to the Client any changes in assigned project personnel.
4. PROJECT COSTS
Pursuant to the state budget act, costs for the study will be covered by a specific state
appropriation for this purpose. FCMAT will not charge the Client for any costs.
5. RESPONSIBILITIES OF THE CLIENT
A. Return current organizational chart(s) that show the Clients management and staffing
structure with the signed copy of this Agreement. Organizational charts should be
relevant to the scope of this Agreement.
B. Provide private office or conference room space for the Teams use during fieldwork.
V12192023 2
Fiscal Crisis and Management Assistance Team California Department of Education 27
Appendix
C. Provide for a Client employee to upload all requested documents and data to FCMATs
online SharePoint repository per FCMATs instructions. Provide FCMAT with the name
and email of the person who will be responsible for collecting and uploading documents
requested by FCMAT with the signed copy of this Agreement.
D. Provide documents and data requested on the Teams initial and supplementary document
request list(s) by the date requested.
All documents and data provided shall be responsive to FCMATs request, in quality
condition, readable and in a usable form. With few exceptions, documents and data
requested are public records and records maintained by LEAs in the routine course of
doing business. Some data requested may require exporting LEA financial system reports
to Microsoft Excel or another usable format agreed to by FCMAT.
All documents shall be provided to FCMAT in electronic format, labeled as instructed by
FCMAT. Upon approval of this Agreement, access will be provided to FCMATs online
SharePoint repository, to which the Client will upload all requested documents and data.
E. Ensure appropriate senior-level staff are available for the orientation and exit meetings.
F. Facilitate access to requested board members, officers and staff for interviews.
G. Facilitate access to requested information and facilities to include, but not be limited to,
files, sites, classrooms and operational areas for observation.
H. Review a draft of the report and return it to FCMAT by the date FCMAT requests with
any comments regarding the accuracy of the reports data or the practicability of its
recommendations. The Team will review this feedback in a timely manner and make any
adjustments it deems necessary before issuing the final report.
I. Return the requested evaluation survey to FCMAT as described below.
6. PROJECT SCHEDULE
Time is of the essence. The Parties acknowledge that the goal of the scope and objectives of
the study under this Agreement is to produce a timely and thorough report that adds value for
the Client. This goal is especially important given that the Client has experienced an event
described under Basis of Agreement that may indicate fiscal distress. To accomplish this
goal, the Parties agree to communicate and mutually agree to honor established time
commitments. These commitments include the Client providing requested documents, setting
and keeping interview appointments and returning comments on the draft report consistent
with the established project schedule.
The following project schedule milestones will be established by FCMAT upon receipt of a
signed Agreement from the Client:
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ACTION TIMELINE
FCMAT provides Client with a draft Draft Agreements are usually provided
Agreement. within 20 business days of the Clients
triggered event.
Client returns partially executed Draft Agreements are valid for 30
Agreement to FCMAT along with the business days.
applicable organizational chart and the
name and email of the of person who will
be responsible for collecting and
uploading documents requested by
FCMAT.
FCMAT returns a fully executed Within five business days of the Clients
Agreement to the Client and identifies the return of the signed Agreement.
project schedule and the lead and other
personnel assigned to the job.
Client uploads initial requested Within five business days of the Clients
documents and data to FCMATs online receipt of the FCMAT document and
SharePoint repository. data request list.
Fieldwork Mutually agreed upon; usually, to
commence within five business days of
FCMATs receipt of requested
documents and data.
Orientation meeting First day of fieldwork
Exit meeting Last day of fieldwork
Follow up fieldwork, if needed (e.g., Mutually agreed upon; usually, within
rescheduled interview, additional five business days of FCMATs request.
interviews).
Client uploads supplemental documents Within two business days of the Clients
and data to FCMATs online SharePoint receipt of FCMATs supplemental
repository. document and data request(s).
Draft report submitted to the Client. To be determined, usually, within four
weeks of the conclusion of fieldwork and
receipt of all documents and data
requested.
Client comments on draft report Within five business days of FCMAT
providing a draft report to the Client.
The Client acknowledges that project schedule deadlines build upon and are contingent on
each previous deadline. Missed deadline dates will affect future deadline dates and ultimately
the timing of the final report. For example, if the Client does not provide requested
documents and data by the specified date, the fieldwork may not be able to proceed as
originally planned.
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FCMAT acknowledges that the Client has an educational program to administer, is balancing
many priorities, and in some cases may have records management difficulties, staffing
capacity issues, staff on various types of leave, or other circumstances, all of which will
affect the project schedule.
The Parties commit to regular communication and updates about the study schedule and
work progress. FCMAT may modify the usual timelines as needed.
7. COMMENCEMENT, TERMINATIONAND COMPLETION OF WORK
FCMAT will commence work as soon as it has assembled an available and appropriate study
team, taking into consideration other jobs FCMAT has previously undertaken, and
assignments from the state, and higher priority assignments due to fiscal distress. The Team
will work expeditiously to complete its work and deliver its report, subject to the cooperation
of the Client and any other related parties from which, in the Teams judgment, it must obtain
information. Once the Team has completed its fieldwork, it will proceed to prepare a report.
In the absence of extraordinary circumstances, FCMAT will not withhold preparation,
publication and distribution of a final report once fieldwork has been completed.
FCMAT may terminate this Agreement at any time if the Client fails to cooperate with the
requested project schedule, provide requested documents and data and/or make staff
available for interviews as requested by FCMAT. If FCMAT terminates the Agreement,
FCMAT will issue a management letter in lieu of the final report explaining the reasons why
FCMAT terminated the Agreement and reporting on any elements for which data was
collected and a conclusion could be reached.
8. INDEPENDENT CONTRACTOR
FCMAT is an independent contractor and is not an employee or engaged in any manner with
the Client. The manner in which FCMATs services are rendered shall be within its sole
control and discretion. FCMAT representatives are not authorized to speak for, represent, or
obligate the Client in any manner without prior express written authorization from an officer
of the Client.
9. RECORDS
The Client understands and agrees that FCMAT is a state agency and all FCMAT reports are
public records and are published on the FCMAT website. Supporting documents and data in
FCMATs possession may also be public records and will be made available in accordance
with the provisions of the California Public Records Act.
FCMAT has a records retention policy and practice, and every effort will be made to
maintain records related to this Agreement in accordance with this policy.
10. CONTACT WITH PUPILS
Pursuant to EC 45125.1, representatives of FCMAT will have limited contact with pupils.
The Client shall take appropriate steps to comply with EC 45125.1.
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11. INSURANCE
During the term of this Agreement, FCMAT shall maintain liability insurance of not less than
$1 million unless otherwise agreed upon in writing by the Client, automobile liability
insurance in the amount required by California state law, and workers compensation as
required by California state law. Upon the request of the Client and receipt of the signed
Agreement, FCMAT shall provide certificates of insurance indicating applicable insurance
coverages.
12. HOLD HARMLESS
FCMAT shall hold the Client, its board, officers, agents, and employees harmless from all
suits, claims and liabilities resulting from negligent acts or omissions of FCMAT's board,
officers, agents and employees undertaken under this Agreement. Conversely, the Client
shall hold FCMAT, its board, officers, agents, and employees harmless from all suits, claims
and liabilities resulting from negligent acts or omissions of the Clients board, officers,
agents and employees undertaken under this Agreement.
13. PUBLIC SAFETY CONSIDERATIONS
Whether due to public health considerations, extreme weather conditions, road closures,
other travel restrictions or interruptions, shelter-at-home orders, LEA closures or other
related considerations, at FCMATs sole discretion, the Scope of Work, Project Costs,
Responsibilities of the Client, and Project Schedule (Sections 2, 4, 5 and 6 herein) and other
provisions herein may be revised. Examples of such revisions may include, but not be
limited to, the following:
A. Orientation and exit meetings, interviews and other information-gathering activities
may be conducted remotely via telephone, videoconferencing, or other means.
References to fieldwork shall be interpreted appropriately given the circumstances.
B. Activities performed remotely that are normally performed in the field shall be billed
hourly as if performed in the field (excluding out-of-pocket costs that can otherwise be
avoided).
C. The Client may be relieved of its duty to provide conference and other work area
facilities for the Team.
14. FORCE MAJEURE
Neither party will be liable for any failure or delay in the performance of this Agreement due
to causes beyond the reasonable control of the party, except for payment obligations by the
Client.
15. EVALUATION
In the interest of continuous improvement, FCMAT will provide the Client with an
evaluation survey at the conclusion of the services. FCMAT appreciates the Clients honest
assessment of the Teams services and process. The Client shall return the evaluation survey
within 10 business days of receipt.
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16. CLIENT CONTACT PERSON
The Clients contact person designated below shall be the primary contact person for
FCMAT to use in communicating with the Client on matters related to this Agreement. At
any time when this Agreement or FCMATs process requires that FCMAT send information,
document request lists, draft report, final report or making other requests for the Client to act
upon, this is the person whom FCMAT will contact. The Client may change the contact
person upon written notice to FCMATs job lead assigned to the study.
Name: Abel Guillen, Deputy Superintendent, Operations and Administration
Telephone: 916-319-0815
Email: aguillen@cde.ca.gov
17. SIGNATURES
Each individual executing this Agreement on behalf of a party hereto represents and warrants
that he or she is duly authorized by all necessary and appropriate action to execute this
Agreement on behalf of such party and does so with full legal authority.
For Client:
_______________________________________________________________
Abel Guillen Date
Deputy Superintendent, Operations and Administration
California Department of Education
For FCMAT:
Michael H. Fine Digitally signed by Michael H. Fine
__________________________D_a_te_: _2_02_5_.0_8_.0_5_ 1_0_:2_6_:3_3_ -_0_7_'0_0_' _______________
Michael H. Fine, Date
Chief Executive Officer
Fiscal Crisis and Management Assistance Team
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