Follow-up Review

Inglewood Unified School District July 2023 PROGRESS REPORT Inglewood Unified School District Follow-up Review July 2023 Table of Contents Introduction and Executive Summary ................................................................ 1 Personnel Management ........................................................................................39 Pupil Achievement ................................................................................................ 121 Financial Management ........................................................................................ 211 Facilities Management ........................................................................................ 395 Glossary of Acronyms .......................................................................................... 491 Introduction and Executive Summary Introduction The Inglewood Unified School District was established in the early 1950s as the successor of the Inglewood School District, which originated in 1888. It encompasses nine square miles in Los Angeles County and is about 13 miles southwest of the city of Los Angeles. Inglewood Unified serves approximately 7,354 transitional kindergarten (TK)-12 students in 16 schools in the city of Inglewood and an adjacent section of unincorporated Los Angeles County (Ladera Heights). The district’s schools include four TK-6 schools, two P-8 schools, four TK-8 schools, one grades 7-8 middle school, two comprehensive high schools, one district-operated TK-8 charter school, one district-operated charter high school and one alternative education high school (9-12). The district-operated TK-8 charter school has 604 students and the district-operated charter high school has 289 students who are included in the 7,354 students referenced above. In addition, the district serves students in one child development center and one adult education school that are not included in the 7,354 students referenced above. Numerous independent charter schools are also in the district service area. At the request of the district, on September 14, 2012, the governor approved Senate Bill (SB) 533 (Chapter 325/2012), bringing the district under state receivership with a state-approved emergency appropriation of $55 million to avoid fiscal insolvency. The district’s previous management made efforts to avoid receivership with last-minute expenditure reductions totaling approximately $22 million, but after years of deficit spending, the district’s structural budget imbalance was too large. The district was projected to have a negative cash balance by March 31, 2013. Stated reasons for fiscal insolvency included: overstating average daily attendance (ADA), understating California State Teachers’ Retirement System payments, understating certificated salary expenses, continued deficit spending, and declining enrollment. State emergency appropriations are sized based on many assumptions. These emergency appropriations are not meant to solve the fiscal problem, but to allow time for the district to make the necessary reductions to correct the structural operating deficit. The funds for the emergency appropriation (loan) to support cash flow in the district were initially to be issued, as provided for in the legislation, by the California Infrastructure and Economic Development Bank (I-Bank). The I-Bank typically would sell bonds to investors to raise the capital for this purpose. Temporary loans were made from the state’s general fund to provide cash flow during the period before the I-Bank bonds were sold. Before they were sold, Assembly Bill (AB) 86, Statutes of 2013, was passed. This legislation superseded the previously authorized I-Bank financing and instead authorized the district, through the California Department of Education (CDE), to request cash flow loans directly from the state’s general fund in an amount not to exceed $55 million at a lower interest rate, saving the district millions of dollars over the life of the loan. Of the $55 million authorized, the district drew $29 million from November 2012 through February 2013 because of negative cash flow projections, or 53% of the emergency state loan funding, leaving a balance of $26 million available. The 2022-23 first interim report combined unrestricted and restricted general fund revenues have increased by approximately $47.6 million since budget adoption while the combined expenditures have increased by approximately $7.0 million, with an unrestricted ending fund balance projected at $27.6 million. The district’s multiyear financial projection (MYFP) showed a reserve for economic uncertainties of 3.00% for 2022-23, 3.00% for 2023-24, and 3.00% for 2024-25. However, the district also included $21.88 million in 2022-23, $18.08 million in 2023-24 Introduction and Executive Summary 1 and $7.63 million in 2024-25 as committed and/or assigned. The district projects to deficit spend in the unrestricted general fund by $4.16 million in 2022-23, $3.72 million in 2023-24 and $10.82 million in 2024-25. The district’s Fiscal Stabilization Plan (FSP) submitted with its first interim report includes ongoing expenditure reductions and revenue increases of $3.08 million in 2022-23, and additional expenditure reductions totaling $5.83 million in 2023-24 and $10.05 million in 2024-25. The county office’s review letter stated that only the 2022-23 cost savings and expenditure reductions were reflected in the first interim MYFP. The district needs to follow through with expenditure reductions and/or revenue enhancements to eliminate the operating deficit and maintain the required reserve for economic uncertainties. The district continues to experience declining enrollment reportedly caused by both declining birthrates and the number of students who reside within district boundaries. Additionally, the number and size of charter schools that operate both within and outside of, but adjacent to, the district’s boundaries have a direct impact on enrollment. Approximately 274 fewer students attended district schools in the 2022-23 school year compared to the prior year. This represents an approximately 10,615 total student decrease (or 59.1%) since its 2003-04 high of 17,969 students. As stated in the county letter, the district’s 2022-23 first interim report enrollment projections for the 2023-24 and 2024-25 school years estimate continuing enrollment reductions of 320 and 214 students for those years, respectively. FCMAT continues to be concerned about external independent audit findings that cite significant deficiencies in internal control in several functional areas of business practice that leave the district’s assets susceptible to misstatement, theft, or fraud. Although the district had greatly reduced the number of audit findings up to 2021-22, it continues to experience new audit findings classified as material weaknesses or significant internal control deficiencies. The 2021-22 fiscal year audit contained 17 audit findings, an increase of nine from the prior year, four of which were considered material weaknesses, and six of which were repeated or partially repeated from the prior year. Four of the new audit findings indicated disallowable ADA, potentially resulting in funding loss. Since 2013, Inglewood Unified has not had to make further draws on the emergency appropriation because of the statewide implementation of the Local Control Funding Formula (LCFF), legislative assistance provided under AB 1840 (discussed in the Changes to State Receivership section below) as well as state and federal coronavirus relief funds to further augment its revenue. However, the additional revenue alone, much of which was one-time funding, will not resolve its solvency issues, which are exacerbated by declining enrollment and failure to adjust facility use to match enrollment. Aside from the increasing costs of salaries and benefits, fiscal recovery efforts were also constrained in past years by ongoing costs to the general fund to cover the annual debt service payment of $1.83 million on the state emergency appropriation, which began in November 2014 and was scheduled to end in November 2033. For the 2018-19 fiscal year, the director of the California Department of Finance granted the district a one-time deferment on this payment. However, this is not debt forgiveness, which means the last loan payment will be adjusted to November 2034. Under state receivership, the superintendent of public instruction (SPI) had historically assumed all the legal rights, duties, and powers of the governing board and appointed a state administrator 2 Introduction and Executive Summary to act as both the governing board and superintendent. This was the case until September 2018, when under AB 1840, the California State Legislature gave the local county superintendent the role formerly assigned to the SPI for this purpose. The district’s five-member governing board continues to serve in an advisory role until the following two events occur: • The district shows adequate progress in implementing the comprehensive review recommendations in the five operational areas of finance, human resources, community relations and governance, facilities, and pupil achievement. • The county superintendent, with concurrence from the superintendent of public instruction and president of the State Board of Education (SBE), determines that the district has built sufficient capacity to self-govern. Even when the governing board resumes control, a trustee will have stay-and-rescind authority until the district has adequate fiscal systems and controls in place, the SPI had determined that the district’s future compliance with the fiscal recovery plan is probable, and the county superintendent of schools, SPI and president of the SBE agree the trustee is no longer needed. The county superintendent’s role of managing fiscal oversight during the period of state receivership continues to be a key element to the district’s recovery since she must assess and approve budgets, receive interim reports and determine the district’s fiscal status as either positive, qualified or negative. The county superintendent’s role during state receivership is no different than her role during normal times of self-governance but was expanded because of the passage of AB 1840. That expansion has brought multiple resources to bear in the district to assist in its recovery. During the first months of state administration, the initial state administrator resigned because of a contractual dispute regarding a collective bargaining agreement signed without the consent of the SPI. The assistant superintendent of business services subsequently became the interim state administrator and remained in this position, filling a dual role, until July 1, 2013. On July 1, 2013, the state appointed a new state administrator, who was called a state trustee based on subsequent legislation, AB 86 (Chapter 48/2013). On October 15, 2015, a new state administrator was appointed and subsequently resigned on April 28, 2017, to accept a superintendent position at another school district. An interim state administrator was appointed and remained until another state administrator assumed her position on August 16, 2017. She announced plans to retire and leave the district in October 2019 with a final retirement date of December 2, 2019. With this disclosure, the county office’s deputy superintendent moved to the district’s central office to assume the role of interim state administrator and assist in providing continuity in leadership upon the departure of the state administrator. According to the revisions in the selection of state administrators provided in AB 1840, FCMAT worked to provide the Los Angeles County superintendent of schools with a list of vetted candidates, and a county administrator was appointed in November 2019. The county administrator announced plans to leave the district in October 2022. The county superintendent appointed the county office’s retired former deputy superintendent as interim county administrator. FCMAT once again worked to provide the Los Angeles County superintendent of schools with a list of vetted candidates, and the county superintendent appointed the current county administrator on January 9, 2023. In October 2021, CalPro, otherwise known as Painters and Allied Trades, notified the district that it would no longer represent the Inglewood classified employees, and an election was held to certify a new union. As of March 4, 2022, California Teamsters Local 911 represents classified employees. The provisions of the existing CalPro agreement will continue to govern the employment relationship between the district and classified employees until a new contract is approved. Introduction and Executive Summary 3 The district placed a $90 million general obligation bond called Measure GG on the ballot on November 6, 2012, and won 86.1% voter approval. Because Measure GG was placed on the ballot as a Proposition 39 bond measure, expenditure of the funds requires the formation of a citizens’ oversight committee, and the district formed this committee as required under Education Code (EC) Section 15282. The district placed a $240 million general obligation bond called Measure I on the November 3, 2020 ballot. The measure won with an 80.8% voter approval, and the proceeds are to be used to repair/upgrade classrooms, including instructional technology, vocational/career education, roofs, plumbing, security/fire safety; remove asbestos, lead paint, mold; provide safe drinking water; and acquire, construct, repair sites, facilities, equipment. Like Measure GG, this ballot measure was a Proposition 39 bond measure and requires the formation of a citizens’ oversight committee. The district reformed its Citizens’ Bond Oversight Committee (CBOC) that was originally assembled to provide oversight of the district’s Measure GG bond. This committee serves as a combined CBOC to also meet the requirement for the Measure I bond. A review of the information provided to the CBOC, information from interviews and a review of actual construction projects during site visits show that the district is continuing with facility improvements. At its November 18, 2015 regular board meeting, the then-state administrator approved a districtwide facilities implementation master plan that identified the needs of each of its school sites, and a capital planning budget for facilities expenditures aligned with the district’s instructional goals. An update was provided at the board’s March 8, 2017 meeting; however, both plans had been shelved, and the district had rolled out several projects incrementally without the benefit of a comprehensive facilities master plan. The district updated its long-range school facilities master plan in November 2018, to reflect its annual capital planning budget and a proposed timeline. During last year’s review, the district hired a consultant to develop a 2022 Facilities Master Plan (FMP). At the time of FCMAT’s fieldwork, staff reported that the district’s FMP has been completed and approved, although no final plan has been shared with FCMAT. However, the district’s Facilities, Maintenance, Operations and Transportation webpage has a link titled Facilities Master Plan 2023. Following the link, a document titled “Inglewood Unified School District Facilities Master Plan 2022” is found. The district’s facilities capacity continues to be more than double than what is needed to house its total student enrollment, and most of the excess capacity is old and in disrepair. As a result, it must maintain its facilities on a maintenance budget that would be considered marginally adequate for a district with less than half as many facilities. Before using its facilities funding, the district should consider aligning its student enrollment capacity with its current and projected student enrollment, which should be reflected in the update to its Facilities Master Plan. The district successfully consolidated two sites, Woodworth Elementary and Monroe Middle School, into one site. During the last review period, the district acted to close Warren Lane Elementary at the conclusion of the 2021-22 school year. Continuing to match district facilities to student enrollment is critical to the fiscal recovery and solvency of the district. The district has had nine state or county administrators/trustees during an 11-year period, creating instability in organizational development and inconsistency in developing and implementing long-range recovery plans. Because of the COVID-19 pandemic, SB 98 (Chapter 24/2020) omitted the district’s eighth comprehensive review. This report is the district’s 11th review and is based on the period from March 2022 to March 2023. 4 Introduction and Executive Summary During this review period, the district’s organizational structure continues to change with additions and losses of personnel. As previously discussed, a new county administrator was appointed in January 2023. Changes in other cabinet-level positions include a new chief business official who began in June 2022 and the chief human resources officer position, which was filled with an interim until a long-time principal was hired for the position in February 2023. As the county administrator continues to focus on improvement and recovery, particular areas will require significant attention. Chief among these continue to be balancing the district’s budget to achieve and maintain fiscal solvency; providing consistent, rigorous, effective first instruction; providing differentiated instruction; instituting a more structured system for monitoring classroom instruction; implementation of a coherent Multi-Tiered System of Supports (MTSS); using data to improve instruction; updating the district’s and its district-operated charter schools’ Local Control and Accountability Plans (LCAPs), including meaningful community partner engagement, and aligning them with the budget; and updating and improving facilities. Also important are working with staff and the advisory board to identify procedures and programs that implement substantial improvements in the district’s fiscal policies and practices; significantly increasing pupil achievement; improving pupil attendance; decreasing the pupil dropout rate; increasing parental involvement; continuing to attract, retain, and train a quality teaching staff; managing fiscal expenditures consistent with current and projected district revenues; instituting a plan to adjust facility use to match enrollment; and prioritizing and implementing facility improvements. The county administrator, the cabinet and the advisory board have many critical roles and responsibilities in the district’s recovery. The district requires continued and consistent leadership that has the ability and capacity to set priorities, implement systemic reform, engage the community, establish high expectations for student achievement, manage resources, ensure accountability and align practices. The district will remain in a perilous position without continuous, consistent and strong leadership, the execution of its multiyear recovery plan, implementation of the LCAP, development of a well-articulated plan for the district’s future and improvement as reflected in the comprehensive review. FCMAT’s 2023 assessment indicates that the district has only made progress in one of the four operational areas reviewed and has not made progress in every standard as is noted throughout the report. Much work remains to be done to achieve full recovery, and that work will be difficult with any additional administrative turnover. Purpose The purpose of this report is to provide the district with the current results of an ongoing systemic and comprehensive assessment of the district’s progress, including recommendations for improvement and recovery in the following four operational areas: 1. Personnel Management 2. Pupil Achievement 3. Financial Management 4. Facilities Management Introduction and Executive Summary 5 This report provides data to the district, the county office, the community and the legislature concerning the district’s progress in implementing the recommendations of the recovery plans and building its internal capacity so that the locally elected school board and staff can effectively manage the four operational areas to eventually exit state receivership and return to local board governance. Beginning with the 2023 review, the fifth operational area of community relations and governance is no longer reviewed since the district has reached the minimum milestone score of six with no individual standard scoring less than four for two consecutive years. State Receivership At the request of the district, on September 14, 2012, SB 533 was signed into law. The bill authorized the appointment of a state administrator and provided a $55 million emergency state loan. Statute authorized FCMAT to complete comprehensive assessments of the Inglewood Unified School District and develop improvement plans in five operational areas. In addition, FCMAT was authorized to assist the state administrator in developing the first annual multiyear financial recovery plan required under paragraph (2) of subdivision (a) of Section 41327 of EC. SB 533 further authorized FCMAT to do the following: • Assist the state administrator in the development of the adopted budget and interim reports. • Recommend to the state superintendent of public instruction any studies or activities that the state administrator should undertake to enhance revenue or achieve cost savings. • Provide any other assistance as described in EC 42127.8. SB 533 requires the Inglewood Unified School District to bear 100 percent of all costs associated with the emergency loan, including the activities of the appointed administrator and FCMAT. SB 533 further intended that the state SPI, through the state administrator, work with the staff and advisory board to identify the procedures and programs that the district will implement to accomplish the following: 1. Significantly raise pupil achievement. 2. Improve pupil attendance. 3. Lower the pupil dropout rate. 4. Increase parental involvement. 5. Attract, retain and train a quality teaching staff. 6. Manage fiscal expenditures in a manner consistent with the district’s current and projected revenues. Also intended by SB 533 was for the SPI, through the state administrator, to do the following: 6 Introduction and Executive Summary • Analyze the identified procedures and programs and, where applicable and appropriate, protect, maintain, and expand them as the budget of the school district allows. The state administrator shall report any findings applicable to this section to the superintendent of public instruction and the education committees of the legislature. • To the extent allowed by school district finances, maintain, under the revised program, core educational reforms that will lead to districtwide improvement of academic achievement, including, but not necessarily limited to, educational reforms targeting underperforming and program improvement schools and other reforms that have demonstrated measurable success. Changes to State Receivership – AB 1840 AB 1840 (Chapter 426/2018) passed the legislature on August 31, 2018, as a budget trailer bill and became effective on September 17, 2018. Among other provisions, AB 1840 provides for several changes in the oversight of fiscally distressed districts and sets forth specific requirements for the district in exchange for providing financial resources under certain circumstances. AB 1840 changes the former state-centric system to be more consistent with the principles of local control. Several duties formerly assigned to the SPI are now assigned to the county superintendent, with the concurrence of the SPI and the president of the State Board of Education. While AB 1840 does not change the definition of or criteria for fiscal insolvency, it does change the structure of how fiscally insolvent districts are administered once a state emergency appropriation has been made. Under AB 1840, the county administrator assigned to the district now reports to the Los Angeles County Superintendent of Schools. If the county administrator elects to not continue, or a determination is made by the county superintendent, with concurrence of the SPI and the president of the SBE, that the county administrator should be replaced, the appointment of the next county administrator would follow the provisions of AB 1840, namely, 1) be selected from a list of candidates identified and vetted by FCMAT, and 2) be appointed jointly by the county superintendent, SPI and president of the State Board of Education. Additionally, AB 1840 established EC 42161, which states the following: (a) For the 2018–19 fiscal year, the Inglewood Unified School District shall do both of the following: (1) Meet the requirements for qualified or positive certification for the school district’s second interim report pursuant to Article 3 (commencing with Section 42130) of Chapter 6. (2) Complete comprehensive operational reviews that compare the needs of the school district with similar school districts and provide data and rec- ommendations regarding changes the school district can make to achieve fiscal sustainability. (b) Beginning with the 2019–20 fiscal year, the Budget Act shall include an appropria- tion for the Inglewood Unified School District, if the school district complies with the terms specified in subdivisions (a) and (c), in the following amounts: Introduction and Executive Summary 7 (1) For the 2019–20 fiscal year, up to 75 percent of the school district’s pro- jected operating deficit, as determined by the County Office Fiscal Crisis and Management Assistance Team, with concurrence with the Depart- ment of Finance. (2) For the 2020–21 fiscal year, up to 50 percent of the school district’s pro- jected operating deficit, as determined by the County Office Fiscal Crisis and Management Assistance Team, with concurrence with the Depart- ment of Finance. (3) For the 2021–22 fiscal year, up to 25 percent of the school district’s pro- jected operating deficit, as determined by the County Office Fiscal Crisis and Management Assistance Team, with concurrence with the Depart- ment of Finance. (c) Disbursement of funds specified in subdivision (b) shall be contingent on the Inglewood Unified School District’s completion of activities specified in the prior year Budget Act to improve the school district’s fiscal solvency. These activities may include, but are not limited to, all of the following: (1) Completion of comprehensive operational reviews that compare the needs of the school district with similar school districts and provide data and recommendations regarding changes the school district can make to achieve fiscal sustainability. (2) Adoption and implementation of necessary budgetary solutions, includ- ing the consolidation of school sites. (3) Completion and implementation of multiyear, fiscally solvent budgets and budget plans. (4) Qualification for positive certification pursuant to Article 3 (commencing with Section 42130) of Chapter 6. (5) Sale or lease of surplus property. (6) Growth and maintenance of budgetary reserves. (7) Approval of school district budgets by the Los Angeles County Superin- tendent of Schools. (d) Funds described in subdivision (b) shall be allocated to Inglewood Unified School District upon the certification of the County Office Fiscal Crisis and Management Assistance Team, with concurrence from the Los Angeles County Superintendent of Schools, to the Assembly Committee on Budget, Senate Committee on Budget and Fiscal Review, and the Department of Finance that the activities described in subdivision (c), as specified in the prior year Budget Act, have been completed. Additionally, by March 1 of each year, through March 1, 2021, the County Office 8 Introduction and Executive Summary Fiscal Crisis and Management Assistance Team, with concurrence from the Los Angeles County Superintendent of Schools, shall report to the Assembly Commit- tee on Budget, Senate Committee on Budget and Fiscal Review, and the Depart- ment of Finance the progress that Inglewood Unified School District has made to complete the activities described in subdivision (c), as specified in the prior year Budget Act. (e) The activities described in subdivision (c) shall be determined in the annual Budget Act based on joint recommendations from the County Office Fiscal Crisis and Management Assistance Team and the Los Angeles County Superintendent of Schools. These recommendations shall be submitted to the Assembly Committee on Budget, Senate Committee on Budget and Fiscal Review, and the Department of Finance by March 1 of each fiscal year, through March 1, 2021, in conjunction with the certification described in subdivision (d). (f) Until June 30, 2019, the Superintendent may waive the reimbursement determina- tion specified in Section 18054 of Title 5 of the California Code of Regulations for Inglewood Unified School District’s 2016–17 fiscal year California state preschool program contract in order to resolve the school district’s outstanding child devel- opment reimbursement liability to the state. AB 181 AB 181 (Chapter 52/2022) approved by the governor on June 30, 2022, as a budget trailer bill and became effective immediately. The relevant provisions of AB 181 are considered a modified extension of the basic concepts in the prior AB 1840 legislation to aid in the district’s fiscal recovery. Additionally, AB 181 established EC 42163, which states the following: (a) By April 1, 2023, the Inglewood Unified School District shall do all of the following: (1) Meet the requirements for qualified or positive certification for the school district’s second interim report pursuant to Article 3 (commencing with Section 42130) of Chapter 6. (2) Complete comprehensive operational reviews that compare the needs of the school district with similar school districts and provide data and rec- ommendations regarding changes the school district can make to achieve fiscal sustainability. (3) Undergo an on-time annual independent audit pursuant to Section 41020 that is free of material weaknesses and that includes an unqualified opinion. Furthermore, the audit shall be free from any material internal control findings. (b) Beginning with the 2022–23 fiscal year, the annual Budget Act shall include an appropriation for the Inglewood Unified School District, if the school district complies with the terms specified in subdivisions (a) and (c), of up to 25 percent Introduction and Executive Summary 9 of the school district’s projected operating deficit, as determined by the County Office Fiscal Crisis and Management Assistance Team, with concurrence with the Department of Finance. (c) Disbursement of funds specified in subdivision (b) shall be contingent on the Inglewood Unified School District’s completion of activities specified in the prior year Budget Act to improve the school district’s fiscal solvency. These activities may include, but are not limited to, all of the following: (1) Updated comprehensive operational reviews that compare the needs of the school district with similar school districts and provide data and rec- ommendations regarding changes the school district can make to achieve fiscal sustainability, with a progress update on each of the recommenda- tions. (2) Adoption and implementation of necessary budgetary solutions. (3) Completion and implementation of multiyear, fiscally solvent budgets and budget plans. (4) Qualification for positive certification pursuant to Article 3 (commencing with Section 42130) of Chapter 6. (5) Sale or lease of surplus property. (6) Growth and maintenance of budgetary reserves. (7) Approval of school district budgets by the Los Angeles County Superin- tendent of Schools. (8) Prompt appointment following a competitive process of a permanent, experienced, and highly qualified chief business official for any vacancy of chief business official. (d) Funds described in subdivision (b) shall be allocated to Inglewood Unified School District upon the certification of the County Office Fiscal Crisis and Management Assistance Team, with concurrence from the Los Angeles County Superintendent of Schools, to the Assembly Committee on Budget, Senate Committee on Budget and Fiscal Review, and the Department of Finance that the activities described in subdivision (c) have been completed. Additionally, by October 1, 2023, the County Office Fiscal Crisis and Management Assistance Team, with concurrence from the Los Angeles County Superintendent of Schools, shall report to the Assembly Committee on Budget, Senate Committee on Budget and Fiscal Review, and the Department of Finance the progress that Inglewood Unified School District has made to complete the activities described in subdivision (c). (e) The activities described in subdivision (c) shall be determined in the annual Budget Act based on joint recommendations from the County Office Fiscal Crisis 10 Introduction and Executive Summary and Management Assistance Team and the Los Angeles County Superintendent of Schools. These recommendations shall be submitted to the Assembly Committee on Budget, Senate Committee on Budget and Fiscal Review, and the Department of Finance by April 1, 2023, and November 1, 2023, in conjunction with the certi- fication described in subdivision (d). (f) Of the moneys apportioned to the Inglewood Unified School District pursuant to this section from an appropriation made for purposes of this section, the school district shall return to the state such moneys if subsequent to the annual appor- tionment it is determined that the school district did not meet the conditions established herein. The Director of the Department of Finance may initiate such return of prior apportionments if the conditions were not subsequently met and may rely on recommendations from the County Office Fiscal Crisis and Manage- ment Assistance Team and the Los Angeles County Superintendent of Schools in making such determination. FCMAT reported the findings regarding the district’s achievement of the requirements in EC 42163(a) and (c), as of March 30, 2023. The district did not meet the requirements listed in subdivision (a) of EC 42163, so FCMAT and the county administrator mutually agreed that further efforts to confirm compliance with the requirements defined in EC 42163(c) would place an unnecessary burden on district staff. FCMAT’s evaluation of conditions and criteria outlined in EC 42163(a) confirmed that the district did not meet the requirements for additional apportionment specified in EC 42163(b). The letter with all findings can be found here. The Return to Local Governance AB 1840 also includes revisions to SB 533 of the requirements for the district’s return to local governance. As a condition of the emergency apportionment, the county superintendent of schools, in consultation with FCMAT, the SPI and the president of the SBE, shall determine the level of improvement needed based on the FCMAT comprehensive review standards before local authority is returned. (EC 41327.1[c]) EC 41326(f) indicates that the authority of the county superintendent of schools, the SPI, the president of the state board or his or her designee, and the administrator, under this section shall continue until all the following occur: (1) (A) After one complete fiscal year has elapsed following the qualifying school district’s acceptance of an emergency apportionment as described in subdivision (a), the administrator determines, and so notifies the county superintendent of schools, the Superintendent, and the president of the state board or his or her designee, that future compliance by the qualifying school district with the recovery plans approved pursuant to paragraph (2) is probable. (B) The county superintendent of schools, with concurrence from both the Superintendent and the president of the state board or his or her designee, may return power to the governing board of the qualifying school district for an area listed in subdivision (a) of Section 41327.1 if performance under the recovery plan for that area has been demonstrated to the satisfaction of the county superintendent of schools, with concurrence from the Superintendent. Introduction and Executive Summary 11 (2) The county superintendent of schools, with concurrence from the Superintendent, has approved all of the recovery plans referred to in subdivision (a) of Section 41327 and the County Office Fiscal Crisis and Management Assistance Team completes the improvement plans specified in Section 41327.1 and has completed a minimum of two reports identifying the qualifying school district’s progress in implementing the improvement plans. (3) The administrator certifies that all necessary collective bargaining agreements have been negotiated and ratified, and that the agreements are consistent with the terms of the recovery plans. (4) The qualifying school district has completed all reports required by the county superintendent of schools and the administrator. (5) The county superintendent of schools, with concurrence from the Superintendent, determines that future compliance by the qualifying school district with the recovery plans approved pursuant to paragraph (2) is probable. Comprehensive Review Process In preparation for the first comprehensive review in 2013, FCMAT updated the legal and professional standards to ensure continued alignment with industry best practices and with applicable state and federal law, including the California Education Code. The standards, which will continue to be used for the annual updates, are applicable to all California school districts. FCMAT monitored the use of the standards during each assessment to ensure that they were applied fairly and rigorously. The eighth review was omitted pursuant to SB 98, Section 102 due to the COVID-19 pandemic. This July 2023 report includes hundreds of recommendations for improvement and recovery related to the identified standards. Recommendations for recovery are designed and intended to affect functions directly at the district, school site and classroom level. Implementing the designated standards and recommendations with this type of depth and focus will result in improved pupil achievement, financial practices, personnel procedures, community relations and facilities management and will hasten the return to local control and governance, which is one of the primary objectives of the recovery process. Prior to the initial assessment, the director of the CDE’s Fiscal Services Division and FCMAT conferred and selected priority standards to assess the district’s condition in the five operational areas. These priority standards are divided among the five operational areas as follows: 20 community relations and governance standards; 28 personnel management standards; 31 pupil achievement standards; 43 financial management standards; and 33 facility management standards (two of which are no longer applicable). Priority standards were selected to ensure that the report measures the district’s progress toward meeting legal and regulatory requirements and restoring the essential functions of an effective district. As previously stated, beginning with this review period, FCMAT will no longer review the community relations and governance standards and report on the district’s progress in this area. This comprehensive review process is a deficit-analysis model. The process of systemic assessment, prioritization and intervention lays the foundation for increasing the district’s capacity and productivity by establishing a baseline measurement against which future progress 12 Introduction and Executive Summary can be measured. The process also serves to engage advisory board members, parents, students, staff and the community in a partnership to improve student learning and engage and inform them about the LCAP. Each annual comprehensive review report will measure progress with a numerical rating and a summary of the district’s progress in the identified priority standards. A recovery process of this magnitude is a challenging, multiyear effort. The county administrator and the district will need to select priority areas on which to focus their efforts during each year of recovery. Understandably, equal progress will not be made in all operational areas as time progresses. The district continues to address issues identified during fieldwork; in some cases, FCMAT was able to report on progress that occurred after the team’s visit. This report also discusses standards and operational areas of deficiency that the district was in the process of addressing during fieldwork. At the time of this report’s publication, the district continued to work on a number of the concerns addressed in this report and thus may have made progress that is not reflected in this document. FCMAT acknowledges and extends its thanks to the county administrator, the district’s advisory board and staff, the community and the Los Angeles County Office of Education for their assistance and cooperation during this ongoing review process. Study Guidelines FCMAT’s approach to implementing the statutory requirements of SB 533 is based on a commitment to an independent and external standards-based review of the district’s operations. FCMAT performed the assessment and developed the improvement plans in collaboration with other external providers. Professionals from throughout California contributed their knowledge and applied the legal and professional standards to the specific local conditions found in the Inglewood Unified School District. Before working in the district, FCMAT adopted five basic tenets to be incorporated in the assessment and recovery plans. These tenets were based on previous assessments conducted by FCMAT in school districts throughout California and a review of data from other states that have conducted external reviews of troubled school districts. The five basic tenets are as follows: 1. Use of Professional and Legal Standards FCMAT’s experience indicates that for schools and school districts to be successful in program improvement, the evaluation, design and implementation of improvement plans must be standards-driven. FCMAT has noted positive differences between an objective standards-based approach and a nonstandards-based approach. When standards are attainable and clearly communicated and defined, there is a greater likelihood they will be measured and met. The standards are the basis of the improvement plans developed for the district. To participate in the review of the Inglewood Unified School District, providers were required to demonstrate how they would incorporate the FCMAT identified standards into their work. Although the standards were identified for the comprehensive review of the district, they are not unique to this district and could be readily used to measure the success of any school district in California. Every standard was measured using a consistent rating format, and each standard was given a scaled rating from zero to 10, indicating the extent to which it has been met. Team members met to discuss findings and test for inter-rater reliability. Introduction and Executive Summary 13 Following are definitions of terms and the rubric used to arrive at the scaled scores. The purpose of the scaled ratings is to establish a baseline against which the district’s future gains and achievements can be measured. Not Implemented (Scaled Score of 0) There is no significant evidence that the standard is implemented. Partially Implemented (Scaled Score of 1 through 7) A partially implemented standard has been met to a limited degree; the degree of completeness varies as follows: 1. Some design or research regarding the standard is in place that supports preliminary development. (Scaled score of 1) 2. Implementation of the standard is well into the development stage. Appropriate staff are engaged, and there is a plan for implementation. (Scaled score of 2) 3. A plan to address the standard is fully developed, and the standard is in the beginning phase of implementation. (Scaled score of 3) 4. Staff are engaged in implementing most elements of the standard. (Scaled score of 4) 5. Staff are engaged in implementing the standard. All standard elements are developed and are in the implementation phase. (Scaled score of 5) 6. Elements of the standard are implemented, monitored and becoming systematic. (Scaled score of 6) 7. All elements of the standard are fully implemented and are being monitored, and appropriate adjustments are taking place. (Scaled score of 7) Fully Implemented (Scaled Score of 8 through 10) A fully implemented standard is complete and sustainable; the degree of implementation varies as follows: 8. All elements of the standard are fully and substantially implemented and are sustainable. (Scaled score of 8) 9. All elements of the standard are fully and substantially implemented and have been sustained for a full school year. (Scaled score of 9) 10. All elements of the standard are fully implemented, are being sustained with high quality, are being refined, and have a process for ongoing evaluation. (Scaled score of 10) 14 Introduction and Executive Summary 2. Conduct an External and Independent Assessment FCMAT used an external and independent assessment process to develop the assessment and improvement plans for the district. This report presents findings and improvement plans based on external and independent assessments conducted by FCMAT staff, separate professional agencies, and independent consultants. Collectively, these professionals and consultants constitute FCMAT’s providers in the assessment process. Their external and independent assessments serve as the primary basis for the review’s reliability, integrity and credibility. 3. Utilize Multiple Measures of Assessment For a finding to be considered valid, the same or consistent information is needed from multiple sources. The assessments and improvement plans were based on such multiple measures. Testing, personal interviews, group meetings, observations, and review and analysis of data all added value to the assessment process. The providers were required to use multiple measurements and confirm their findings from multiple sources as they assessed the standard. This process allowed for a variety of methods of determining whether the standards were met. All school district operations that affect student achievement (including governance, fiscal, personnel and facilities) were reviewed and included in the improvement plan. 4. Empower Staff and Community Senate Bill 533 requires that the recovery plan include specific training for advisory board members and staff who have personnel and management policy-making and advisory responsibilities to ensure that the district’s leadership team has the knowledge and skills to carry out its responsibilities effectively. The success of the improvement plans and their implementation depend on an effective professional and community development process. For this reason, empowering staff and the community is one of the highest priorities and emphasizing this priority with each of the five teams was critical. Thus, the report consistently calls for and reports progress on providing training for board advisory members, staff and administrators. Of paramount importance is the community’s role in local governance. Parental involvement in the education of their children is an important component to student success. Re-engaging parents, teachers and support staff is vital to the district’s success. Parents in the district care deeply about their children’s future and want to participate in improving the school district and enhancing student learning. The community relations section of the previous reports provided recommendations for engaging parents and the community, a significant focus of the LCAP process, in a more active and meaningful role in their children’s education. They also provided recommendations for engaging the media in this effort and increasing the number and frequency of media reporting on the district’s recovery progress. Although FCMAT is no longer reviewing this operational area, the district should continue to include prior recommendations in its recovery efforts, and the Los Angeles County Superintendent of Schools has the responsibility to continue to monitor continued improvement in this area. Introduction and Executive Summary 15 5. Engage Local, State and National Agencies It is critical to involve various local, state and national agencies in the district’s recovery; the engagement of state-recognized agencies and consultants in the assessment and improvement process emphasized this. The CDE, city and county interests, California Collaborative for Educational Excellence (CCEE) and professional organizations have expressed a desire to assist and participate in the district’s recovery. Study Team The study team was composed of the following members: For FCMAT: Shayleen Harte, Deputy Executive Officer Leonel Martínez, FCMAT Technical Writer For Personnel Management: School Services of California, Inc. For Pupil Achievement: California Collaborative for Educational Excellence For Financial Management: Debbie Riedmiller, CFE, FCMAT Intervention Specialist Diane Branham, FCMAT Chief Analyst Jennifer Noga, CFE, FCMAT Intervention Specialist Erin Lillibridge, CFE, FCMAT Intervention Specialist David Thurston, FCMAT Consultant For Facilities Management: John Von Flue, FCMAT Chief Analyst Brad Pawlowski, FCMAT Consultant Dean Bubar, FCMAT Consultant Jack Colvard, FCMAT Consultant 16 Introduction and Executive Summary Summaries of Findings and Recommendations in Each of the Four Operational Areas The full report includes all the various findings and recommendations for fiscal and operational recovery in the four operational areas reviewed. Each finding and recommendation addresses a previously identified professional or legal standard. Following is a summary of the major findings and recommendations for each operational area, which are presented in greater detail in the body of this report. This assessment is the product of data collection and analysis of the district’s status at a specific point in time since state administration began. It is important to note that the ratings of the first report produced July 2013 indicated the district’s status prior to state administration. The second through the 11th reports have each been based on the district’s status from the prior year’s rating date to the next year’s rating date, except for the district’s eighth report, which was omitted according to SB 98, Section 102 due to the COVID-19 pandemic. This report is the district’s 11th comprehensive review, will be dated July 2023 and is based on the district’s status since July 2022. The Tables of Summary Scores below provide not only the average score for each operational area of the report but also provides the number of standards in which scores were under a four. While past performance and future plans are acknowledged in portions of the report, they were not considered in the application of FCMAT’s rating rubric. The assessment team began fieldwork the last week in January 2023 and concluded in early-March 2023. The district has addressed some preliminary findings reported during the assessment and is benefiting from the assessment team’s ongoing feedback. Introduction and Executive Summary 17 18 Introduction and Executive Summary serocS yrammuS fo elbaT 3202 yluJ 2202 yluJ 1202 yluJ 0202 yluJ 9102 yluJ 8102 yluJ 7012 yluJ 6102 yluJ 5102 yluJ 4102 yluJ 3102 yluJ aerA lanoitarepO sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA sdradnatS egarevA 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS 4 rednU erocS /snoitaleR ytinummoC deweiver regnol oN 0 08.7 0 50.7 1 02.6 2 05.5 4 58.4 8 87.3 71 04.1 02 54.0 02 50.1 ecnanrevoG rep dettimO 2 23.6 1 86.6 2 75.6 1 06.6 1 23.6 2 34.5 8 00.4 81 28.2 72 63.1 62 64.1 tnemeganaM lennosreP ,89 BS 201 noitceS 0 91.5 11 84.4 02 78.3 61 78.3 71 49.3 12 86.3 42 23.3 52 78.2 82 30.2 91 32.3 tnemeveihcA lipuP ot eud 91-DIVOC 91 00.4 61 62.4 32 07.3 02 18.3 52 82.3 33 44.2 43 61.2 33 59.1 04 33.1 14 91.1 tnemeganaM laicnaniF cimednap 7 60.5 8 61.5 11 17.4 7 31.5 7 92.5 9 56.4 61 49.3 71 18.3 72 95.2 92 42.2 tnemeganaM seitilicaF Personnel Management A district’s Human Resources (HR) Department plays an important role in students’ academic and cocurricular success by providing an effective and efficient recruitment, selection, and orientation and induction program for all employees. In addition, personnel management plays a vital role in the district’s fiscal recovery. With 73.29% of its unrestricted general fund expenses going toward employee compensation according to 2021-22 state-certified data (the last year for which state- certified data is available), the district’s ability to regain fiscal solvency requires continued and sustained improvements in this area. The personnel management section of the comprehensive review assessed the district based on 28 priority standards in eight categories. The HR Department showed minimal improvements in 2023. Specifically, five of the 28 standards (18%) improved in implementation and sustainability over time, and scores were increased accordingly. Unfortunately, some standard scores declined as improvements made in prior years were not sustained as has been the case for the prior two review periods. In 2021, 10, or 36%, of the standard scores declined. Only three, or 11%, of the standard scores saw a decline in 2022. In 2023, six standards, or 21%, fell into this category. Still, the evidence showed continued and sustained growth in some areas despite continued transition in district and department leadership. The July 2013 average scaled score for the subset of priority standards that the department’s recovery plan is based on was 1.46. During the early years of recovery, the district struggled to implement many standards. By July 2017, all standards were at least partially implemented, and the average scaled score increased to 5.43. In July 2018, the average scaled score increased to 6.32. The July 2019 average scaled score rose to 6.60, indicating another year of growth as well as sustainability. SB 98 omitted the 2020 review due to the COVID-19 pandemic. The July 2021 average scaled score decreased slightly to 6.57, indicating that despite the COVID-19 pandemic and a significant reorganization of the department, many standards continued to be sustainable. In 2022, the scaled score average rose slightly to 6.68 demonstrating sustainability of many standards, but with some standards showing no growth, and in a few cases, a decline. In 2023, the district had a similar pattern with some standards showing improvements and others showing a decline with a scaled score of 6.43, showing no year-over-year growth. This is the fifth consecutive review in which the district has met the minimum average rating score of six or above. The district should focus on the standards that are scoring less than a four related to employee evaluations. Organization and Planning The county administrator continued to send correspondence to all district staff regarding board policy updates during this review period. However, no board policies or administrative regulations related to personnel were updated. The position of director of employee relations and policy management, established in January 2022 and assigned to the HR Department, was given responsibility for monitoring and updating board policies. The position was eliminated during the review period. The district reports that an independent contractor will be used to bring all district board policies and administrative regulations up to date. For the third consecutive year, the department experienced some restructuring. At the time of FCMAT’s fieldwork, the chief HR officer position had been vacant for a few months. An interim chief HR officer was in place and a long-time district principal had just been hired for the position, resulting in yet another year of transition and uncertainty. A review of the department website’s menu of services, updated job descriptions, and organizational charts given to FCMAT provide a clearer picture of the work assigned to each position, an improvement over the prior reporting period. Introduction and Executive Summary 19 Employee Recruitment/Selection Evidence submitted during the prior reporting period included the Human Resources Division 2020-21 Annual Report, which was presented to the county administrator/board during a regularly scheduled meeting. The HR Department’s goals were clearly stated during the presentation and were descriptive and narrowly focused on areas that will have a positive effect on all staff: recruitment, retention, position control, staff evaluations, and building professional capacity in HR staff through professional support and training. Department goals are specific and list intentional actions to reach department objectives. The department did not present a 2021-22 annual report to the county administrator/board during this review period. And similar to the prior year, there is no evidence indicating that the department has a plan of activities that are expected to be implemented and measured to ensure goal achievement. The district continues to operate without a personnel commission; however, strong evidence indicates that the committee rules are being implemented. For this review period, the district submitted a narrative document with links to evidence related to this and other standards. The narrative document states that the “bargaining units made the decision not to reinstate [the personnel commission].” It also states that the interim chief HR officer was providing training to HR staff on the personnel commission rules and management employees on the classified selection process. No evidence was submitted to indicate that a petition for termination of the merit system according to EC 45319 had been filed or that training on the merit system rules was provided to management employees since the time of the last review. Onboarding procedures, including required trainings and notices, are implemented consistently. The HR Department provides hiring managers with individual support and training on the selection and hiring procedures and nondiscrimination in employment, which is a best practice. The district has developed a recruitment plan that includes attendance at job/career fairs. Human Resources maintains an active partnership with California State University (CSU) Dominguez Hills, Concordia, Loyola Marymount University and Teach for America as a teacher pipeline to the teaching profession. The 2022-23 recruitment budget included new employee hiring and induction program incentives, funded participation in a virtual job fair at CSU Dominguez Hills and a Los Angeles County Office of Education (LACOE) induction program job fair. A review of recruitment files indicates some improvement related to hiring timeline, and interviews with principals indicated significant progress in ensuring sites are fully staffed at the beginning of the school year. Induction and Professional Development The HR Department’s process for providing new employees with all required notices and in-service trainings is systematic, monitored, and adjustments are made when necessary. Specifically, the HR Department continues to provide and document that all employees receive the annually required legal notices including, but not limited to, child abuse reporting, bloodborne pathogens, drug- and alcohol-free workplace, sexual harassment, diversity training, bullying, Integrated Pest Management Plan, safety, use of seclusion and restraint, youth suicide prevention, and nondiscrimination. Additionally, the district uses Keenan Safe Schools online training for mandatory new hire orientations, which includes understanding sexual harassment, bloodborne pathogens, preventing workplace violence, new employee training sessions, and mandated reporter training. These training sessions occur prior to the first day of employment. The rate of compliance with annual legal notices for new and existing employees increased substantially during the review period. 20 Introduction and Executive Summary The HR Department continues to use standardized forms for complaints and for the Americans with Disabilities Act interactive process. Additionally, information about Uniform Complaint Procedures (UCP), including how to file a complaint, can be located on the main landing page of the district HR webpage. The executive director of state and federal programs, assigned to the Educational Services Department, has been designated as the UCP complaints officer for those concerning school employees. The complaint form can be accessed by clicking the link for UCP Complaint Form, which was updated in March 2023. Forms are now available in English and Spanish. Operational Procedures Sick and vacation tracking reports provided to FCMAT show that although employee absenteeism is improving, this continues to be an area of concern. A sample report of 245 full-time classified employees indicated that 114 used all their sick leave for the 2021-22 school year. In December 2022, 73 employees from the same sample group have used more than half their sick days for the 2022-23 school year. Supervisors also report that HR is responsive to long-term absence needs and tries to meet requests for long-term substitutes efficiently. The HR staff has attended leave training this year to gain a shared understanding of employee leaves. After two consecutive years of reorganization, significant turnover in department staff, and leadership uncertainty, the department experienced additional staffing changes during the reporting period. Despite continued change and the short tenure of staff hired during the current and prior year reporting periods, desk manuals are complete and in the process of being updated. Desk manuals were a primary source of training as department staff settled into their roles. Desk manuals reside in Airtable, a cloud-based project management system, and are accessible to all department staff. HR, Payroll, and Business Services continue to hold regularly scheduled monthly meetings to coordinate employee issues, provide training, and prepare cross-departmental procedures and forms, which are stored in Airtable. For example, evidence provided to FCMAT included agendas from monthly meetings on leaves of absence, CalPERS reporting, payroll corrections, payments for overtime, stipends, and retro pay. Staff members in these departments continue to report that the meetings are systemic and are essential in ensuring that employee situations are handled correctly. In between meetings, individual staff members report that they easily communicate with the other departments as situations arise. While HR and Business Services continue to be located in different buildings on the district office campus, this has not created barriers to their communication. Their shared use of Airtable has also assisted in improving their interdepartmental communications. Use of Technology The district uses the LACOE software application HRS for position control and HR functions. The district implemented the BEST financial module for fiscal functions, transitioning away from PeopleSoft. The district provided evidence of training given to school site and district office staff to facilitate this implementation. The BEST budget module will not be fully integrated until the district has implemented the Human Capital Management (HCM) module, a HR and payroll system for position control, personnel management, and payroll accounting. The district has a tentative date for the BEST HCM implementation, but the implementation date depends on the accuracy and consistency of the data in HRS. The district needs to be prepared to work closely Introduction and Executive Summary 21 with LACOE staff during the conversion and verification process as this process is complex and time consuming. The district will benefit from the regularly scheduled meetings between the business office and HR. Training for HR department staff will be especially important as the district begins transitioning from the current HRS system to the BEST HCM system. Planning and coordination will be required to ensure that the training plan takes into consideration the need for staff to participate in trainings, collaborate, and continue to meet the district’s HR and payroll needs. The personnel action form (PAF) and position control processes were previously reported to be duplicative, resulting in inefficiencies that delay the posting of vacancies and interfere with the timely filling of positions. In response to these concerns, the district revised the written procedures to include a quarterly review by the HR staff to identify processing delays. The district provided evidence of Position Control/Requisition Process Training on September 7, 2022. The training slide deck has detailed workflow including the responsible staff member for each step. Evaluation/Due Process Assistance The Education Code requires that all certificated employees with permanent status be evaluated at least every other year. Classified employees with permanent status must be evaluated annually as provided for in the collective bargaining agreement. The HR Department provided supervisors with information regarding certificated and classified evaluation timelines and procedures as well as lists of employees to be evaluated. The certificated evaluation list identified 351 certificated nonmanagement employees to be evaluated and included their names, job title, school site, and status as permanent, probationary, temporary, or intern. The list did not identify probationary certificated employees as Prob 0, Prob 1, or Prob 2. Because nonreelection decisions must be made by March 15 for Prob 2 employees, the evaluation list should include these designations and clearly communicate that principals notify HR of any non-reelections of Prob 2 employees no later than the end of February so that non-reelection meetings can be held prior to the statutory deadline. A best practice is to ensure that the final evaluation be completed prior to these non- reelection meetings. While evidence indicates that supervisors are notified of their requirements to evaluate certificated and classified employees, the district does not hold them accountable. According to the personnel report provided by the district, no certificated nonmanagement evaluations have been completed since the 2019-20 school year. This document indicated 165 (47%) employees have been evaluated in the last five years, 57 (16%) have not been evaluated in five or more years, and 129 (37%) have never been evaluated. Additionally, the report indicates that only 68 classified employees (15%) have been evaluated during the reporting period. Further, 52 (12%) have not been evaluated in five or more years, and 148 (33%) have never been evaluated. The number of employees who have never been evaluated and those not evaluated in more than five years is alarmingly high. Holding supervisors accountable is outside of the department’s control as the chief HR officer does not supervise or evaluate supervisors other than those in the department. The chief HR officer should regularly report to the county administrator the extent to which supervisors are evaluating assigned staff. It is the responsibility of the county administrator and the district leadership team to develop and implement a system of accountability in this area. Development of a plan to address employee evaluations should be a high priority for the department and the district. 22 Introduction and Executive Summary Employer/Employee Relations During this review period, the Inglewood Teachers Association (ITA) and the district entered into several memorandums of understanding (MOUs) including classroom coverage, teachers on special assignment, Childhood Development Center teacher extra-duty pay, and LCFF TK-3 Grade Span Adjustment. The district and ITA continue to engage in Interest-based Bargaining and are working together to solve problems in a collaborative manner. The district and California Teamsters Local 911 reached agreement on a collective bargaining agreement and at the time of FCMAT’s fieldwork, the agreement had not yet been ratified. The grievance process is documented in the collective bargaining agreements, which along with the forms, are easily accessible to administrators and staff on the HR Department webpage on the district’s website. One formal classified grievance was filed during this review period and was resolved at level II. Evidence suggests that the parties are working together to resolve concerns at the lowest possible level. Pupil Achievement For this progress report, FCMAT reviewed 31 standards in pupil achievement, with the ratings of 20 standards increasing, 10 remaining the same and one decreasing. Overall, in the pupil achievement standards for the 2023 review period, the district’s average scaled score increased from 4.48 at the last review to 5.19. In addition, no standard score was lower than a four. The district has made many efforts to develop and plan around these standards and build intentional momentum to move towards full implementation of the standards. Many staff interviewed expressed confidence in the district’s educational services team’s capacity and focus. In the continuing improvement effort reflected by advancing rating scores on the rubric, the district must continue to focus on all elements of each standard being fully and effectively implemented, monitored and becoming systematic (scale score of six or above). The district continues to implement and monitor the 2018-23 Strategic Plan that district leadership, in collaboration with site administrators, staff, and community members developed, communicated and disseminated. The district has developed its 2021-23 Instructional Plan to guide the actions from the Strategic Plan. Paramount to effective implementation is a continued focus on clarity and coherence in implementing elements of the plan. In collaboration with LACOE and the CCEE, the district regularly monitors the actions of its Strategic Plan, specifically the four IUSD Instructional Performance Indicators for 2022-23, which include: 1) High School Graduation and College/Career Readiness, 2) K-12 Literacy, 3) K-12 Special Education Programs, and 4) Chronic Absenteeism. The IUSD Systemic Instructional Review (SIR) progress monitoring tool is used for quarterly reviews with the district leadership team. The district’s LCAP and Strategic Plan, as well as each school’s School Plan for Student Achievement (SPSA), delineate the issue of low student achievement throughout the district. Specifically, the district has high percentages of students who do not meet grade-level standards and high school students failing one or more classes. Higher percentages of English language learners (ELLs), students with disabilities (SWDs) and African American students are in these categories than are other student groups. The district’s leadership has identified, and FCMAT has verified, several contributing factors. However, the greatest barrier to student success is the lack of consistent, rigorous, effective first instruction. In collaboration with LACOE and with Introduction and Executive Summary 23 CCEE support, the district continues to refine and monitor systematic plans for instructional improvement as detailed in the Theory of Action Plan and the SIR progress monitoring tool. The district held biweekly principals’ meetings that included routine district business, but also consistently focused on collaboration, planning and professional learning intended to train principals as instructional leaders. Professional learning for principals focused on walk-throughs to calibrate the level of instruction in every classroom. In addition, a partnership with New Leaders has provided more opportunities through coaching and targeted group activities to strengthen and support effective instructional leadership. New Leaders is also working with district leadership to strengthen and align site level support. Evidence indicates the district-disseminated Cycle of Inquiry (CoI) data analysis template is used at school sites as part of the required CoI process. Documentation provided to FCMAT validated that grade level/content area data review meetings generally occur as required by the district. Samples of completed CoI forms from individual teachers and some grade level/content area teams demonstrate wide variability in how completely and effectively the CoI process is being implemented within and across grade levels, content areas, and school sites. The CoI process does not yet result in specific, measurable goals with instructional action plans to address the high percentage of students scoring below grade-level standard on district-required assessments. The district has negotiated weekly banked time with an early student dismissal on Tuesdays, which began during the 2022-23 school year, to provide uninterrupted and protected time for teachers to use the CoI process. In addition, all staff have been trained in professional learning communities (PLCs) processes and protocols. FCMAT visited classrooms along with principals and district leadership at every school site throughout the district during this review period. In addition, district administration conducted classroom visits with all principals as part of an ongoing process to calibrate the expectation of instructional delivery aligned to standards. All school sites appeared orderly and students were on-task. On-task behavior was consistently observed; however, active student engagement in classrooms was inconsistent across the district. While evidence indicated that the district’s instructional priorities in literacy were implemented in many classrooms, there was little consistent engagement of students in academic conversations observed across school sites. Additionally, the quality of designated ELD instruction varied classroom-to-classroom and a need for integrated ELD strategies continues to be a priority. Improved coherence was observed across the district in common language and principals referring to the district’s instructional priorities. The district increased the use of digiCoach to support common language/common understanding in three focus areas. The primary focus was student engagement. Principals were expected to regularly conduct classroom visits and provide feedback to teachers. The district continues to use Dynamic Indicators of Basic Early Literacy Skills (DIBELS), i-Ready and Achieve 3000 as universal screening and progress monitoring tools across grades. The district has implemented a 10/10/95 expectation (10% growth in students meeting the literacy benchmark, 10% decrease in students scoring in the “far below” category of achievement, and 95% participation on required assessments). This has resulted in increased participation and improved student outcomes. The district continues to develop elements of a coherent MTSS plan for all students. The foundation of MTSS is effective first instruction. The district priority should be to define and 24 Introduction and Executive Summary establish effective first instruction in all classrooms. While Tier 1 and 2 interventions have been outlined, further development of Tier 2 is needed to define options for students who are not responding to initial interventions. The implementation of accelerated learning teachers (ALTs) has supported Tier 2 instruction at the elementary schools. Additionally, Tier 3 supports need to be developed, and the district must adopt a reading intervention program for students in grades 4-8 who are two or more years behind. The district has a defined assessment system. It has defined what assessments are required and when they are to be administered on a yearly calendar, specifying both formative and summative assessments. There was evidence of a regular review of assessment data at the district level. However, the evidence continues to be minimal that the wide variety of data generated from the common assessments is systematically used for assessing program effectiveness and guiding curricular decision-making. Interviews indicate the district continues to make a concerted effort to ensure that all secondary core classes and electives meet A-G requirements. In 2021-22, the district experienced a significant increase from 86.2% to 91.1% in the cohort graduation rate, up from 87.2% in 2019-20 and 88.5% in 2018-19. The district’s graduation rates are disproportionate by race/ethnicity and gender, and certain groups have a lower graduation rate, including SWDs and ELLs who had an 87.6% and 85.7% graduation rate, respectively, in 2021-22. According to Ed-Data, the percentage of cohort graduates meeting University of California/ California State University (UC/CSU) course requirements increased from 52.4% in 2019-20 to 62.2% in 2020-21 and dropped to 46.8% in 2021-22. Like with graduation rates, the district’s percentage of cohort graduates meeting UC/CSU course requirements is disproportionate by race/ethnicity and gender, and certain groups are less likely to meet UC/CSU course requirements, including SWDs and ELLs who had 25% and 34.1% of students meeting UC/CSU course requirements, respectively, in 2021-22. District leadership continues to identify the least restrictive environment (LRE) as an area that needs constant communication of expectations and the building of capacity of site leadership and instructional staff to help the district make appropriate placement decisions during individualized education program (IEP) meetings. Interviews and information reviewed indicate some progress is being made in this area, which requires that programs for special education students meet the LRE provision of the law and the quality criteria and goals established by the IDEA. The district’s professional development plan is well-developed and connected to the instructional priorities. The district employs four instructional coaches that have primarily elementary experience. Coaches serve specifically at school sites, providing direct service to classroom teachers. During this review period, instructional coaches were being used to support new teachers. Classroom observations, staff interviews, principals’ meetings and the review of data submitted indicate continued progress and improvement towards identified goals. The district’s plans are well-developed, with a continued need for focused implementation at the school and classroom levels to ensure that all students achieve at higher levels. The overall collaboration and commitment of the district’s leaders to implementing the plans’ elements and strategies should continue to provide improvement and progress in the coming school year. Introduction and Executive Summary 25 Financial Management The financial management section of this comprehensive report assessed the district based on 43 FCMAT standards. The district received an average rating of 4.00, a decrease from the score of 4.26 achieved in the prior review period. Two standards received a score of zero-not implemented; 35 standards received scores between one and seven-partially implemented; and six standards received scores between eight and 10-fully implemented. The chief business official (CBO) was hired in June 2022 and oversees the Fiscal Services, Facilities Planning and Construction, Food Services, Information Technology (IT), and the Maintenance, Operations and Transportation (MOT) departments. During this review period, an executive director of risk management position was created, and Risk Management was reassigned and is now overseen by the CBO. At the time of FCMAT’s fieldwork, all six of the department head positions were filled, four of which were filled during this review period by a promoted or newly hired employee. The business office continues to experience staff turnover in several positions, and at the time of fieldwork, two of the business office positions were vacant and four of the 15 positions were filled and/or refilled during this review period. The ongoing restructuring of the Business Services Department and continual turnover of business office staff has made it extremely difficult for the district to make progress in improving operational processes and procedures. FCMAT continues to recommend that business office staffing be reviewed to ensure staff have the necessary skills, are properly trained and held accountable to perform essential functions. Business office and/or school site and department administration and support staff continue to need and/or desire initial or additional training in numerous areas such as the new financial system, Excel, accounting, budget, account codes, student information system (SIS), associated student body (ASB), purchasing, inventory and payroll, as applicable to their job duties. Interviews indicated that communication between the Business Services and HR departments has improved; however, communication between some business office staff members has been strained during this review period, and some staff do not respond timely to requests for information from department and school site staff. The district should establish a districtwide standard for responding to email and telephone messages, such as one business day, and hold all employees accountable for meeting it. Budget and Multiyear Financial Projections The district adopted its 2022-23 budget within the statutory timelines and conducted public hearings for its 2022-23 LCAP and proposed budget as required. The county office of education approved the budget. The district filed its 2021-22 second interim and 2022-23 first interim budget reports within statutory timelines; both reports were certified as positive. The LCAP must be aligned with the budget and MYFPs. The LCAP lists the district’s goals and actions to achieve those goals and should be an integral component of the budget. The criteria and standards forms for the 2022-23 adopted budget indicate that the budget includes the expenditures necessary to implement the plan, and the county office approved the district’s LCAP. However, the 2022-23 budget and first interim assumptions narrative documents and/ or PowerPoint presentations do not include discussion of the plan, which makes it difficult for readers to easily discern the extent of its alignment with the budget at each reporting period. The district should include a brief discussion and/or summary of the LCAP expenditures in the budget narratives. Additionally, the information provided in the online board agenda backup 26 Introduction and Executive Summary materials at each financial reporting period should include all the major assumptions used to develop the budget and multiyear financial projection and should be based on the most current data available. The district’s 2022-23 first interim report projects deficit spending of $4.16 million in the unrestricted general fund in 2022-23, $3.72 million in 2023-24 and $10.82 million in 2024-25. Reserves for economic uncertainties were projected to be 3.00% for each year of the projection. The district also included committed and/or assigned designations of $21.88 million in 2022-23, $18.08 million in 2023-24 and $7.63 million in 2024-25 as part of the components of the ending fund balance. The total available reserves with the fund balance designations for the unrestricted general fund are 14.81% in 2022-23, 12.61% in 2023-24, and 7.36% in 2024-25. The district’s pattern of deficit spending in the unrestricted general fund could severely affect its recovery plan and long-term fiscal solvency. The district’s 2022-23 first interim report submitted to the county superintendent included an updated FSP reflecting expenditure reductions of $5.83 million in fiscal year 2023-24 and an additional $10.1 million in 2024-25; however, those cost reductions were not included in the two subsequent fiscal years’ projections. Instead, the district’s MYFP included an unallocated expenditure reduction of $2.11 million in 2023-24 and $4.07 million in 2024-25. These arbitrary amounts placed in the budget have a direct correlation to the district’s ability to meet the required reserve for economic uncertainties; in fact, when removed from the MYFP, the district’s general fund reserve percent for 2023-24 and 2024-25 decreases to 1.86% and negative 0.51%, respectively. As stressed in previous years, the district’s FSP is a multiyear strategic blueprint critical to the district’s ability to maintain fiscal solvency, and it is imperative that it be updated and included in each of the district’s financial reports. The county office noted that the district’s unrestricted general fund is projected to decrease from a beginning balance of $31.8 million in 2022-23 to a projected ending balance of $13.10 million in 2024-25, a decline of approximately $18.70 million or 58.10% over three years. As a result, the county continues to be concerned about the projected trend of deficit spending and its impact on the district’s ability to maintain the required reserve for economic uncertainties in future years and recommends the district monitor the causes of deficit spending to prevent further erosion of the fund balance. Various staff members from the Business Services and Educational Services departments have continued to conduct monthly online meetings with each principal to discuss budgets and staffing, and interviews indicated that these meetings have been well received. A monthly budget meeting schedule was also recently developed for department leaders. During the prior review period, the business office revised the Budget Development Process for School Sites and Department manual that provided some information to administrators about budget development, and the business office provided school sites with budget development worksheets. The budget development manual and budget allocations were reviewed with principals, and the budget worksheets were to be completed and returned to the business office. At the time of FCMAT’s fieldwork for the current review period, the former CBO and senior executive director of fiscal services, who were the primary business office staff members responsible for 2022-23 budget development, were no longer with the district. School site budget development worksheets were provided to FCMAT for 2022-23; however, no forms/worksheets were provided for department budgets, and interviews indicated that department leaders were not involved in development of their 2022-23 budgets. The district should develop and implement standardized budget worksheets for department budget allocations. Introduction and Executive Summary 27 Board meeting minutes show that three or more advisory board members were present at all the meetings except for the December 13, 2022 board workshop that included a High Level Review of the Budget – First Interim, where two advisory board members were present. It is essential for the advisory board members to regularly attend meetings to gain a broader understanding of their role and the district’s fiscal matters. Additionally, new advisory board members should initially receive, and all existing advisory board members should continue to periodically receive, governance and school finance training. Although the district has implemented best practices for some critical functions that include some basic budgeting processes, it has not implemented proper budget monitoring or proper alignment of budget to actual expenditures. The district has continued to work on implementing processes and procedures and ensure both Business Services and HR departments’ staffs have been trained correctly on position control. The Business Services and HR staffs meet monthly to review and reconcile position control; however, actual payroll and position control are still not reconciled. The position control report used in the preparation of the 2022-23 first interim budget did not align with actual payroll. With the turnover in staff, it seems that the district is mainly using the report to account for all positions but no longer integrates it with actual payroll information for budgetary accuracy. The way that the district accounts for overtime, extra-duty pay, stipends and substitutes shows these types of positions as vacant in the position control system. This method is not conducive to determining actual vacancies. In addition, savings for unfilled positions should be recognized throughout the year to provide a realistic budget projection and financial position. Audit and Internal Control The development and implementation of an internal control system that includes written operational procedures, proper separation of duties and other control activities designed to safeguard district assets and to detect and deter fraud is essential. Processes and procedures for routine business activities are the foundation of strong internal control, and implementation, routine monitoring and enforcement are essential to their effectiveness. The district continues to work on improving processes and procedures supporting its system of internal control, but struggles in some key areas. The district has an established practice to regularly review and update board policies, but employee turnover in key management positions limited much of that work during this review period. Additionally, the district continues to struggle with the alignment of the appendix listed in Board Bylaw 9270-Conflict of Interest with its organizational structure. The continual restructuring of the organization has created confusion for staff regarding the official authorized positions and/or staff members holding these positions. Although the district had greatly reduced the number of audit findings over the past several years, the 2021-22 audit contained 17 findings, an increase of nine from the prior year, six of which were repeated or partially repeated from the prior fiscal year. The audit report continues to cite significant deficiencies and material weaknesses in internal control in several functional areas leaving the district’s assets at risk for misstatement, theft or fraud; four of the new audit findings indicated disallowable ADA, potentially resulting in funding loss. The district should ensure that all audit findings are reviewed with applicable staff and that best practices and recommendations are implemented timely. 28 Introduction and Executive Summary The district has assigned responsibility for internal audit to the director of fiscal services position. At the time of FCMAT’s fieldwork, this individual had only served as the interim director for a couple of weeks; therefore, the district has made no progress to implement a structured internal audit process. The district still does not have an audit committee, nor does it have a fraud prevention program. The district has various procedure manuals for accounting, payroll and purchasing as well as some separate written procedures that are not included in these manuals. Some staff have resumed efforts to establish and update operational processes and procedures for the Business Services Department. However, there is no established process or timeline for reviewing and updating procedures as changes within the department take place. All processes and procedures documents and manuals should be reviewed and updated at least annually and should be posted in a centralized online source. Communication, training and routine monitoring of processes and procedures are essential to ensure control activities are successful and effective. Turnover in key positions in the HR, Student Support Services, and Business Services departments, including all three fiscal leadership positions – the CBO, senior executive director of fiscal services, and director of fiscal services – challenges the district’s ability to maintain strong systems of internal control and communication. The district should routinely review, update and monitor operational procedures and provide staff training. The operational procedures should be followed by all employees and should not be overridden by management. Student Attendance and Associated Student Body The district has established processes for properly collecting, recording, maintaining and reporting enrollment and attendance in a consistent manner districtwide; however, those processes weakened in execution during this review period. Inconsistent practices were reported across school sites, discrepancies were noted in attendance reporting for home hospital and special education programs, the audit included findings in independent study and attendance accounting, and the California Longitudinal Pupil Achievement Data System (CALPADS) Fall 1 reporting deadline was missed. The district should monitor the implementation of established enrollment and attendance procedures, and provide staff with regular and timely training on these procedures. Student enrollment and attendance is the responsibility of the executive director of student support services under the leadership of the county administrator. The district has established a team that is responsible for implementing strategies that ensure student data is appropriately reconciled and reported through CALPADS. However, due to continued turnover and/or restructuring of positions, the district continues to struggle in achieving a collaborative process that ensures all aspects of student enrollment, attendance, and CALPADS reporting requirements are seamless. The district has improved some of its processes for identifying students attending and exiting nonpublic schools (NPSs); however, current processes do not ensure that enrollment and attendance are captured and reported to the state for all students attending nonpublic schools. Interviews indicate that staff continue to note students listed on NPS invoices that are not Introduction and Executive Summary 29 enrolled in the SIS and vice-versa. Attendance for students presented in invoices but not listed in the SIS is not included in the totals reported to the state. Because the SIS information drives the data submitted through the CALPADS reporting process, and is critical to both the level of state funding provided through the LCFF and student testing, having accurate student data entered in the SIS in a timely manner is imperative. The information should be routinely reconciled with CALPADS and other ancillary systems, including those for child nutrition. It is also essential to ensure that all required supporting documents agree with reports submitted to the state, and that the documents are retained in a centralized location for audit. During fieldwork, FCMAT learned that one school site had been closed for several weeks because of a gas leak. The school transitioned students to remote learning, and recorded attendance as it would for a regular school day. FCMAT informed district administrators that they should follow the state’s established procedures for school closures and file a J-13A waiver and revise any recorded attendance in the SIS to a school closure day to ensure the proper attendance reporting for apportionment purposes. The CBO contacted the CDE and the county office for direction, and advised the Educational Services and Student Support Services departments that attendance in the SIS should be revised to note a school closure. The issue was unresolved at the end of fieldwork because the site was still closed. FCMAT is concerned that district leadership was unaware of proper attendance accounting procedures during school closures. The district adopted BP 3452-Student Activity Funds, in February 2019, but it is unclear if the district communicated with the school sites regarding the specifics of this policy. The district continues to lack standardized procedures on how ASB organizations are to operate and to ensure adequate internal controls are implemented. Some school sites use FCMAT’s Associated Student Body Accounting Manual, Fraud Prevention Guide and Desk Reference, and the district has partially completed a document titled ASB Financial Guide Inglewood Unified School District (For Schoolsite Use). However, the district has not yet implemented previous recommendations to provide written internal procedures for ASB that provide direction to staff, ensure effective administrative oversight, and clearly define the roles and responsibilities of all personnel involved in managing ASB funds. The lack of internal control and oversight at the school sites and the district office could lead to misappropriation of ASB funds. At the time of FCMAT’s fieldwork, the newly appointed interim director of fiscal services had not yet been assigned ASB oversight. The district has centralized the TK-8 and middle schools’ ASB deposit and payment functions at the district office. During the prior review period, the district began implementing the ASBWorks accounting software at its high schools; however, one high school has not transitioned to this software program. The district should complete implementation of the ASBWorks software and ensure that duties are properly segregated for ASB functions that have been centralized at the district office. The district should provide initial and annual training to all employees who are responsible for ASB functions and make the training mandatory for all applicable employees and administrators. Staff indicated that the district has directed ASBs to sell caps and gowns for graduation ceremonies. Education Code (EC) 49011 states that pupils shall not be required to pay a fee for participation in an educational activity; therefore, the district should ensure that students are not charged any unallowable fees. 30 Introduction and Executive Summary Other Related Areas Management Information Systems – Although work has begun on documenting equipment to be included in a replacement plan, the district lacks a formalized lifecycle replacement plan and annual budget for critical network infrastructure equipment. This lack of planning will create unplanned expenses and outages when systems cease to function. The district has not implemented previous recommendations to create a formalized lifecycle replacement plan and annual budget for all its technology equipment. The district has vacancies in two critical positions within the IT Department. Vacant database administrator (DBA) and application support specialist positions have left the district dependent on contractors for critical student information system support, training, and state reporting (CALPADS) processes. Inventory – The district contracted with a vendor in 2015 to perform a physical inventory of items with an original cost of $500 or more, and a fixed asset report was completed. No person or department has been responsible for maintaining all the records, including asset acquisitions and disposals, since that inventory was completed. In February 2021, the district approved an agreement with another vendor to perform a capital asset inventory, which was completed in June 2021; however, additions and disposals are still not tracked. Findings included in the last several audit reports include material weaknesses specifically related to inventory and fixed assets and contributed to the qualified opinion given by the external auditor in the 2021-22 audit. The district should establish procedures that require all equipment and other fixed assets valued at $500 or more to be properly tagged for inventory purposes. The employee assigned to maintain the fixed asset inventory system and all employees involved in the asset identification, tagging and reporting process should be properly trained and cross-trained. The district should consider completing an annual inventory until roles and responsibilities are assigned and inventory procedures are properly implemented. The district surplus inventory and salvage procedures do not support appropriate reporting requirements, which necessitate inventory to be tracked as to the time and mode of disposal. The procedures do not provide for proper internal control, possibly allowing valuable items to be disposed of without proper review. Procedures should be updated and/or developed and implemented to ensure proper processes are followed, and all applicable employees should be trained in their use and held accountable for following them. The processing and disposal of surplus assets and instructional materials should be centralized to eliminate the opportunity for loss or theft. Food Service – The 2021-22 unaudited actuals show that the cafeteria ending fund balance was approximately $3.0 million; however, the 2021-22 audit report included various adjustments totaling a negative $1.2 million, which reduced the fund balance to $1.8 million. The state increased the net cash resources limit from three to six months of expenditures, and because the district did not exceed the new limit, the spend-down agreement is no longer needed. The district should ensure that year-end accounts receivable and accounts payable transactions are posted correctly and review all balance sheet items during year-end closing; any audit adjustments should be posted timely and accurately. The district should continue to monitor the cafeteria fund net cash resources calculation to ensure that the state limit is not exceeded. During the prior review period, the director of fiscal services’ duties included oversight of food service, along with the two food service operations managers. During this review period, Introduction and Executive Summary 31 the district restructured the Food Services Department and promoted one of the operations managers to director of food services and backfilled the operations manager position. The district should ensure that all staff who are assigned to oversee and operate the program are adequately trained and supervised, are knowledgeable about budget and program requirements, and properly analyze the financial aspects of the food service program monthly to evaluate profitability and identify any areas of concern. Special Education – The 2021-22 unaudited actuals show an unrestricted general fund contribution of $23.0 million, or 67.80% of total special education expenditures. The 2020-21 unaudited actuals contribution was $22.8 million, or 80.51%. The statewide average unrestricted general fund contribution to special education was 64.44% for 2020-21 and 64.3% for 2021-22. The Southwest Special Education Local Plan Area (SELPA) is responsible for the supervision of all special education programs and coordination of regionalized services between member districts. In 2018-19, the member districts voted to partially support the regionalized services costs for three years with a SELPA subsidy, decreasing the amount the district pays for regionalized services. However, the subsidy was eliminated in 2021-22. The district’s 2021-22 cost for regionalized services was $1.47 million, which includes a reduction of $619,484 for various revenue offsets. The district still contracts with outside agencies for all speech-related services including assessment, progress monitoring and IEP participation; however, now the district meets monthly with the agencies. Additionally, a district program specialist participates in all IEPs, so agencies are not exclusively managing these services provided to students. As mentioned in previous reports, this can create a conflict of interest. It is not a best practice to use an outside agency to assess students, determine the level of service they need and provide services. In some prior review periods, the district was not tracking costs related to students who were attending nonpublic school/licensed children’s institutions (NPS/LCI) and any that might have been eligible for reimbursement of costs exceeding the annual threshold amount. In the current review period, the district filed four claims for reimbursement. Clear communication between the Special Education and Business Services departments regarding the criteria for qualifying students, roles, relationships and responsibilities should be established so that the district uses all opportunities to generate income. Additionally, the district should formalize all new processes and procedures in writing to ensure continuity should there be a turnover in staff. The district continues to take steps to increase communication between the Business Services and the Special Education departments. Administrators from both departments were meeting weekly to review and discuss the SELPA’s excess costs billings and budget. However, due to turnover in staff, communication between the departments has become difficult, especially because of the steep learning curves of the new staff. Communication is necessary and should include topics such as: budget development and monitoring, maintenance-of-effort requirements, staffing, student counts, and program needs. To provide for consistent data districtwide, the HR Department should be included when meeting topics involve staffing issues. Communication between the SELPA and the district is critical to proper receipt, budgeting and monitoring of special education income and expenses. As the voting member representative for the district, it is important that the county administrator continue to attend all SELPA superintendents’ meetings, and the CBO/designee should continue to attend SELPA business meetings. Interviews indicated that the district is considering adding staff in the Special Education Department. Given the continued increased cost of the district’s special education programs, 32 Introduction and Executive Summary the district should regularly analyze program operations to identify opportunities for improved efficiencies. Changes that would further increase ongoing expenditures should be avoided. Transportation – The Annual Report of Pupil Transportation previously filed with the state is no longer required. In the absence of the report, applicable district departments should mutually determine the management data and information necessary to properly manage transportation expenses. To track and control costs, expenses need to be budgeted and charged to the proper accounts throughout the year to provide opportunities for variance analysis. In addition, the Transportation Department manager should have access to the budget and routinely monitor it. Per the 2021-22 unaudited actuals, the district spent approximately $2.6 million on transportation, and its entitlement was $962,143. Interviews indicated that the district does not provide any home-to-school transportation, other than for its own special education students. However, the 2021-22 unaudited actuals show that the district spent just under $1 million for general education home-to-school transportation and is projected to spend approximately $700,000 in 2022-23. Additionally, costs for “other miles,” which includes field trips, athletic events, summer school and trips between school sites, are considered instructional costs to the user program. Although these are initially expensed to the transportation function, they should be transferred (with supporting documentation) to other functions to offset the expenditures from the home-to-school transportation function. District staff should review and evaluate all transportation expenditures to ensure they are properly allocated between home-to-school transportation and special education transportation. The district typically provides most of its own special education student transportation; however, due to a lack of capacity, some students are transported by LACOE. To contain costs, the district should evaluate the cost of transportation provided by the county office to determine whether the district can transport these students more cost effectively. Invoices from all outside providers should be reviewed, reconciled with student data and approved prior to payment. Detailed information should also be obtained from fuel vendors and be regularly reviewed and analyzed; any anomalies should be investigated. Agreements with transportation contractors should be approved prior to commencement of services, and the district should ensure that it complies with EC 39802 when awarding transportation contracts. The deputy chief maintenance and operations officer should be a resource in determining the most cost-effective means of transportation; budget accuracy may be improved if all transportation contracts were managed by the Transportation Department. The 2022-23 enacted state budget included a provision for additional ongoing funding as reimbursement to school districts based on prior year eligible home-to-school transportation expenditures. The district may be eligible for additional funding of up to 60% of total transportation costs, less the LCFF home-to-school transportation add-on, provided the district complies with certain requirements. Specifically, the district must develop, and the county administrator must adopt, a transportation service plan on or before April 1, 2023 that describes how the district will offer transportation services to its students and how it will prioritize services for grades TK-6 and low-income students. The plan must be updated by April 1 each year thereafter. Risk Management – During this review period, the district experienced significant turnover and vacancies in key positions overseeing and administering its risk management program, which led to lapses in certain monitoring activities during the review period. Risk management Introduction and Executive Summary 33 responsibilities have been split between HR and Business Services, with HR continuing to oversee employee health benefits and Business Services responsible for workers’ compensation, property and liability insurance, and safety programs. Consequently, the district should ensure the two departments meet regularly to resolve issues related to workers’ compensation. The district continues to comply with Governmental Accounting Standards Board (GASB) 75, which requires the district to update its actuarial report for other post-employment benefits (OPEB) every two years. Based on the actuarial projection and pay-as-you-go method of payment, the district’s OPEB payment will increase each fiscal year and reach a cost of approximately $1.0 million in 2033-34. Facilities Management During the 2023 review, the facilities team again assessed 31 standards in 10 categories. FCMAT visited the district January 30-February 2, 2023. During this time, the team interviewed selected district staff, which included district administrative, maintenance, operations, and facilities personnel, and members of the facilities and bond oversight committees, and visited sites including TK-12 schools, dependent charter schools, adult school, continuation school, district warehouse/maintenance yard and transportation. During site visits, the team also met with site administrators and custodians, as well as various district and facilities personnel. In addition, the team requested and reviewed documentation to verify and support the facility standards. Of the 31 facilities management standards reviewed, scores for 17 remained the same, five improved and nine declined. Overall, the average rating decreased from 5.16 in 2022 to 5.06 in 2023. Two years ago, the district hired a deputy chief maintenance and operations officer. This staff member came out of retirement to take on the district’s challenges in these operational areas. The district’s hiring of an experienced and knowledgeable person for this position is continuing to result in progress and improvement in some areas. Stability in this and other management positions is vital to the district’s progress. With frequent staff turnover in the past, the district’s historical knowledge was lost and progress towards goals stifled. This year, the district hired a deputy chief facilities planning and construction officer, a position that should help it move forward more proactively in addressing its facilities’ needs. The communities served by Inglewood Unified have shown consistent support for facilities funding. In 1998, the district passed Measure K, providing $131 million in general obligation (GO) bond funds. Another bond, Measure GG, was passed in November 2012, resulting in an additional $90 million in GO bonds. And most recently in 2020, yet another GO bond, Measure I, was passed authorizing $240 million in funding to support facility improvements, repairs and construction. School Safety FCMAT found that all school sites in the district have developed their Comprehensive School Safety plans in alignment with BP 0450 and EC 32280-32289, which requires site specific considerations; however, not all were adopted by their SSC as required. A copy of the district’s Comprehensive School Safety Plan was prepared and supplied to sites and posted on the district website as well as links to each school’s safety plan although the links were not working at the time of FCMAT’s visit. As in prior editions, the district incorporated additional policies, protocols and procedures into its and site plans such as the pandemic safety guidelines. Site surveys indicated earthquake and fires drills were 34 Introduction and Executive Summary conducted in accordance with board policy. Although most school sites had emergency telephone numbers and evacuation route maps posted in offices and classrooms, FCMAT found six sites not in full compliance, with some missed postings and outdated, missing, or incorrect information. The District Safety Committee has not been active as records indicate it has not met since February 2021. However, the chief of police has taken a role in school site safety planning including conducting districtwide safety surveys, meeting with site administrators, assisting sites with updating their Comprehensive School Safety plans and providing safety training to SSCs and staff throughout the year. Site principals reported that fire alarm systems operate correctly except for Worthington Elementary, Oak Street Elementary, and Payne Elementary. Public address systems at Morningside High, Oak Street Elementary, Kelso Elementary, Highland Elementary, Payne Elementary and Worthington Elementary are either not working or are incapable of addressing the entire site. School sites were found mostly clean and free of fire or life hazards; however, they were not free of visible debris and litter. All district school and work sites had safety data sheet (SDS) binders listing the current cleaning products used and the safety information on their handling and use. No training on SDS occurred during this or the prior review period. In addition, the Hazard Communications Program document developed in 2019 is no longer in use. The Injury and Illness Prevention Program (IIPP) in the district office is dated 2017 and contains some outdated information. The district offers ongoing training to its employees through a web-based application and maintains a record of all annual training. However, no districtwide workplace safety training was completed in this review period. The district continues its struggle with key standardization. The district has not fully implemented a standardized lock system and, as a result, many staff must carry many keys. At times during site visits, staff (including administration, maintenance and operations and custodial) could not open areas as they did not have or could not find the appropriate key. However, key controls are in place. The site principal or administrator is responsible for the issuance, security, and return of all keys to the site under his or her supervision. During this review period, Payne Elementary was updated sitewide with a new key and lock system that has one master key. The district does not have a board policy or district standard specifically addressing outside lighting. In addition, assessment of exterior lighting is not part of any district inspection process or reporting. However, evidence of repair and improvement of outside lighting was found in the work order system and during site visits. All sites had exterior lighting that appeared to operate, and no complaints or concerns were noted. Facility Planning The district’s BP 7110-Facilities Master Plan was last revised in February 2019 stating, in part, that a district advisory committee may be established to solicit broad input into the planning process. The committee is to serve in an advisory capacity to the county administrator. Committees in the district related to facilities include the CBOC, the District Real Property Advisory Committee, the Asset Management Advisory Committee, and the School Closure and Consolidation Committee, but the previously active District Real Property Advisory Committee has not met for several years. Introduction and Executive Summary 35 The district’s facilities capacity continues to be more than the amount needed to house its student enrollment. Over the last few years, the district has made some progress in “right sizing” its facilities by removing or demolishing some excess portable classrooms, consolidating a couple of school sites and closing one site. Staff reported that the district’s FMP has been completed and approved, although no final plan has been shared with FCMAT. The district’s Facilities, Maintenance, Operations and Transportation webpage includes a link titled Facilities Master Plan 2023 that leads to a document named Inglewood Unified School District Facilities Master Plan 2022. This FMP appropriately includes a district introduction, current site conditions, and analysis and recommendations. Facilities Improvement and Modernization Measure I, passed in 2020, and authorized $240 million in bonds. The language for this measure states it is for Inglewood Unified School District student safety/health/achievement, classroom repair measure to repair/upgrade classrooms, including instructional technology, vocational/ career education, roofs, plumbing, security/fire safety; remove asbestos, lead paint, mold; provide safe drinking water; and acquire, construct, repair sites, facilities, equipment. The district has previously applied and was approved for $40 million in Los Angeles World Airports (LAWA) funding. In prior reviews, the district believed that additional projects may be eligible to receive LAWA funds and continued appeals to LAWA for reconsideration. No updated information was provided regarding the LAWA funding. During this review period, the district has made progress on several maintenance projects and has finished renovating Oak Street Elementary. Major infrastructure needs continue to exist throughout the district. During FCMAT’s visit, Morningside High was closed due to a failure in the main natural gas line. As previously stated, the district hired a deputy chief facilities planning and construction officer and completed an update on the FMP. Both efforts should prove beneficial in improving the district’s facilities. The district should continue efforts to maintain project records and drawings to assist with future planning and projects. These documents, along with the FMP, will outlast current staff and become the base of detail knowledge for the district’s future facilities improvements. Facilities Maintenance and Operations The district’s routine restricted maintenance account (RRMA) budgeted $6,015,006 for the 2022-23 fiscal year, this includes allocations for staff, repairs, parts and contracted services and exceeds the requirement under EC 17070.75. The CBO indicated that at the end of the 2021-22 fiscal year, the RRMA was not fully expended. However, the CBO reported that, based on spending patterns, the RRMA will be fully expended for the 2022-23 fiscal year. As noted earlier, the district’s facilities are more than double what is needed to serve its enrollment, yet the RRMA budget is based on the district’s overall budget and not the total facilities that need to be maintained. In the past, the district provided FCMAT with a multiyear plan for preventive and deferred maintenance; however, no documents to support this area were provided for this or the prior review period. The district does not use its work order system to proactively schedule preventive maintenance work such as inspections and servicing of HVAC, roofing, fire alarms, etc. Sites 36 Introduction and Executive Summary reported that the majority of responses to work orders are timely; however, most maintenance activities are reactionary rather than preventive. LACOE conducted eight facilities inspections required under the Williams Act between February 2022 and April 2022 using the Facilities Inspection Tool (FIT). Six of the schools reviewed received overall ratings of good and two received exemplary ratings. The district performed preinspections on the sites to be inspected by LACOE but did not conduct facilities inspections on school sites not visited by LACOE. The district should conduct inspections on the remaining sites. During field visits, FCMAT found that only one principal provided feedback to the chief deputy maintenance operations and transportation officer using a form titled Buildings and Grounds Inspection Checklist. This document allowed the principal to monitor and give feedback on services received and facility conditions. The district does not maintain a position or system to track utility costs or energy consumption, nor does it utilize an energy management system (EMS) although it had a limited computerized system in the past. However, in its facilities planning, the district includes energy efficient upgrades, and Measure I language included a goal and purpose to upgrade facilities for energy efficiency. The district continues to keep adequate maintenance records and has inventoried all the tools, materials, supplies and equipment that are stored at the maintenance and operations/central warehouse facility. Unused or unnecessary tools and equipment are discarded. While the district did not provide FCMAT with evidence of periodic inventory counts to verify its accuracy, the warehouse appeared mostly organized with few tools stored out of place. Employees who are required to perform custodial, maintenance, or groundskeeping work are generally provided with adequate supplies and equipment to perform their tasks. The district has procedures for evaluating the quality of work performed by the maintenance and operations staff; however, evaluations for all maintenance, custodial, groundskeeping and transportation staff members were not completed for 2020-21 or 2021-22 and were still in progress for 2022-23. Accountability is an issue in several places and should be a priority moving forward. Ongoing examples include: the custodial practices of periodically checking and cleaning restrooms are not done consistently throughout the district; and the groundskeeping crew regularly did not follow the established schedule. Instructional Program Issues EC 35293 requires districts to develop and maintain a plan to ensure equality and equity of all their school site facilities. The district’s BP 7110, last revised in February 2019, states that one component of the FMP should be the “Analysis of the safety, adequacy, and equity of existing facilities and potential for expansion, including the adequacy of classrooms, school cafeterias and food preparation areas, physical activity areas, playgrounds, parking areas, and other school grounds.” The newly created FMP appropriately includes a district introduction, current site conditions, and analysis and recommendations. The Introduction section includes district historical background, mission and goals, district schools list and map, demographic trends, capacity analysis and enrollment trends. The current site conditions section, titled Ready from Day One, includes Introduction and Executive Summary 37 academic goals and performance, facility conditions, site and building conditions, functionality and health and wellness. And the Analysis and Recommendations section includes information by school site such as an overview of each site, existing conditions, proposed opportunities, and associated costs. The district has implemented a team approach to groundskeeping duties in which teams visit sites routinely to maintain the grounds, landscaping, and gardening. Site principals indicated varied satisfaction with the landscaping conditions at their sites, and many believe that the groundskeeping staff is inadequate to maintain facilities appropriately. A lack of clear roles and conflicting responsibility was evident between the district landscaping/groundskeeping crew and site staff. A Groundskeeping Handbook that had been drafted and provided in prior reviews, has not yet been finalized and implemented. Having a handbook would help to establish acceptable conditions and procedures, determine staffing needs, facilitate training and assist with accountability of staff. Throughout the years, the district has continued to suffer from a loss of enrollment and changing leadership in key decision-making positions. This creates a problem with changing priorities and continuity of information, which is evident in the number of times the district has “refocused” project types and plans for districtwide facilities. This continues to be an area of concern. 38 Introduction and Executive Summary Personnel Management Personnel Management 39 40 Personnel Management 11..11 OOrrggaanniizzaattiioonn aanndd PPllaannnniinngg PPrrooffeessssiioonnaall SSttaannddaarrdd ThThee llooccaall eedduuccaattiioonnaall aaggeennccyy ((LLEEAA)) hhaass cclleeaarrllyy ddeefifinneedd aanndd ccllaarriififieedd rroolleess ffoorr bbooaarrdd aanndd aaddmmiinniissttrraattiioonn rreellaattiivvee ttoo rreeccrruuiittmmeenntt,, hhiirriinngg,, eevvaalluuaattiioonn aanndd ddiisscciipplliinnee ooff eemmppllooyyeeeess.. FFiinnddiinnggss 11.. ThThee ccoouunnttyy aaddmmiinniissttrraattoorr ccoonnttiinnuueedd ttoo sseenndd ccoorrrreessppoonnddeennccee ttoo aallll ddiissttrriicctt ssttaaffff rreeggaarrddiinngg bbooaarrdd ppoolliiccyy uuppddaatteess dduurriinngg tthhiiss rreevviieeww ppeerriioodd.. KKeeyy pprroocceesssseess tthhaatt aarree iiddeennttiififieedd aass bbooaarrdd ppoolliiccyy,, mmuusstt bbee cclloosseellyy aalliiggnneedd wwiitthh aaddmmiinniissttrraattiivvee rreegguullaattiioonn ttoo eennssuurree tthhaatt ddiissttrriicctt ppoolliiccyy aanndd pprroocceedduurreess aarree iimmpplleemmeenntteedd.. 22.. NNoo bbooaarrdd ppoolliicciieess oorr aaddmmiinniissttrraattiivvee rreegguullaattiioonnss oonn ppeerrssoonnnneell wweerree uuppddaatteedd ttoo tthhee CCaalliiffoorrnniiaa SScchhooooll BBooaarrddss AAssssoocciiaattiioonn ((CCSSBBAA)) tteemmppllaattee aanndd aaddoopptteedd dduurriinngg bbooaarrdd mmeeeettiinnggss ssiinnccee tthhee llaasstt rreevviieeww.. PPoolliiccyy uuppddaatteess aarree pprroovviiddeedd bbyy CCSSBBAA fifivvee ttiimmeess ppeerr yyeeaarr ((JJuullyy,, OOccttoobbeerr,, DDeecceemmbbeerr,, MMaarrcchh,, aanndd MMaayy)).. ThTheessee uuppddaatteess aarree iinncclluuddeedd iinn tthhee HHuummaann RReessoouurrcceess ((HHRR)) aannnnuuaall ccaalleennddaarr,, wwhhiicchh wwiillll hheellpp tthhee ddeeppaarrttmmeenntt ssttaayy oonn ttaasskk wwiitthh ppoolliiccyy uuppddaatteess.. 33.. BBooaarrdd BByyllaaww ((BBBB)) 99000000--RRoollee ooff tthhee BBooaarrdd iinnddiiccaatteess tthhaatt tthhee bbooaarrdd wwiillll hhiirree aanndd eevvaalluuaattee tthhee ssuuppeerriinntteennddeenntt aanndd eessttaabblliisshh ppoolliicciieess ffoorr hhiirriinngg aanndd eevvaalluuaattiinngg ootthheerr ppeerrssoonnnneell.. BBBB 99000000 aallssoo pprroovviiddeess tthhaatt tthhee bbooaarrdd wwiillll sseett ppaarraammeetteerrss ffoorr nneeggoottiiaattiioonnss wwiitthh eemmppllooyyeeee oorrggaanniizzaattiioonnss aanndd rraattiiffyy ccoolllleeccttiivvee bbaarrggaaiinniinngg aaggrreeeemmeennttss.. 44.. BBooaarrdd PPoolliiccyy ((BBPP)) 44000000--CCoonncceeppttss aanndd RRoolleess pprroovviiddeess tthhaatt tthhee ddiissttrriicctt wwiillll aattttrraacctt aanndd rreettaaiinn hhiigghhllyy qquuaalliififieedd ssttaaffff.. BBPPss 44111111//44221111//44331111--RReeccrruuiittmmeenntt aanndd SSeelleeccttiioonn aallssoo pprroovviiddee tthhaatt tthhee ssuuppeerriinntteennddeenntt oorr ddeessiiggnneeee wwiillll ddeevveelloopp ffaaiirr,, ooppeenn,, aanndd ttrraannssppaarreenntt rreeccrruuiittmmeenntt aanndd sseelleeccttiioonn pprroocceesssseess aanndd pprroocceedduurreess tthhaatt eennssuurree eemmppllooyyeeeess aarree sseelleecctteedd bbaasseedd oonn ddeemmoonnssttrraatteedd kknnoowwlleeddggee,, sskkiillllss,, aanndd ccoommppeetteennccee aanndd nnoott oonn aannyy bbiiaass,, ppeerrssoonnaall pprreeffeerreennccee,, oorr uunnllaawwffuull ddiissccrriimmiinnaattiioonn.. BBPPss 44111111//44221111//44331111 ssttaattee:: FFoorr eeaacchh ppoossiittiioonn,, tthhee SSuuppeerriinntteennddeenntt oorr ddeessiiggnneeee sshhaallll pprreesseenntt ttoo tthhee BBooaarrdd oonnee ccaannddiiddaattee wwhhoo mmeeeettss aallll qquuaalliifificcaattiioonnss eessttaabblliisshheedd bbyy llaaww aanndd tthhee BBooaarrdd ffoorr tthhee ppoossiittiioonn.. NNoo ppeerrssoonn sshhaallll bbee eemmppllooyyeedd bbyy tthhee BBooaarrdd wwiitthhoouutt tthhee rreeccoommmmeennddaattiioonn oorr eennddoorrsseemmeenntt ooff tthhee SSuuppeerriinntteennddeenntt oorr ddeessiiggnneeee.. 55.. BBPPss 44111111//44221111//44331111 wweerree uuppddaatteedd dduurriinngg tthhee AApprriill 22001199 bbooaarrdd mmeeeettiinngg.. 66.. BBPP 44003300--NNoonnddiissccrriimmiinnaattiioonn iinn EEmmppllooyymmeenntt pprroohhiibbiittss ddiissccrriimmiinnaattiioonn aaggaaiinnsstt jjoobb aapppplliiccaannttss aanndd ddiissttrriicctt eemmppllooyyeeeess bbaasseedd oonn pprrootteecctteedd cchhaarraacctteerriissttiiccss ssuucchh aass aaggee,, ggeennddeerr,, ggeennddeerr iiddeennttiittyy,, rreelliiggiioouuss ccrreeeedd oorr ddrreessss,, mmaarriittaall ssttaattuuss,, oorr sseexxuuaall oorriieennttaattiioonn.. 77.. BBPPss 44111155//44221155--EEvvaalluuaattiioonn//SSuuppeerrvviissiioonn pprroovviiddeess tthhee ccrriitteerriiaa ttoo eevvaalluuaattee cceerrttiifificcaatteedd aanndd ccllaassssiififieedd eemmppllooyyeeeess.. ThThee ssuuppeerriinntteennddeenntt oorr ddeessiiggnneeee iiss ttoo eennssuurree tthhaatt eevvaalluuaattiioonn rraattiinnggss hhaavvee uunniiffoorrmm mmeeaanniinngg tthhrroouugghhoouutt tthhee ddiissttrriicctt.. EEvvaalluuaattiioonnss aarree ttoo bbee uusseedd ttoo rreeccooggnniizzee eexxeemmppllaarryy sskkiillllss aanndd aaccccoommpplliisshhmmeennttss oorr ttoo iiddeennttiiffyy aarreeaass nneeeeddiinngg iimmpprroovveemmeenntt.. Personnel Management 41 8. BP 4315-Evaluation/Supervision provides the criteria for evaluating administrative staff. The evaluation is linked to the district’s vision and goals and school improvement plans along with referencing evaluation criteria based on the California Professional Standards for Education Leaders (CPSEL). 9. The board’s policies on dismissal/suspension/disciplinary action of certificated employees are contained in BP 4118 and provide that the superintendent or designee shall ensure that, consistent with the law, disciplinary actions are taken in a consistent, nondiscriminatory manner and are appropriately documented. There is no current board policy for the dismissal/suspension/disciplinary action of classified employees. 10. BP/Administrative Regulation (AR) 4300.11-Governing Board/Administrators/ Confidentials Working Relations were adopted on June 29, 2015, the board policy was updated on January 11, 2017, and the administrative regulation was updated April 17, 2019. These policies stipulate the rights and personnel practices related to certificated and classified administrators and confidential employees. In implementing this policy and regulation, the district no longer provides certificated administrators with vacation days and moved all certificated administrators to a positive work calendar. 11. The district has developed and implemented selection procedures that ensure nondiscrimination in hiring (see Standard 3.11). 12. A review of the district website indicates that most personnel policies were last updated in 2014. The policies adopted in 2014 are accessible via the district website and interspersed with the updated 2019, 2020, and 2021 policies. In addition, some of the board policies have been updated, but the applicable administrative regulations have not. In some cases, administrative regulations have been updated, and the accompanying board policy has not. Examples of these issues are as follows: The board policy has been updated, but the administrative regulation has not: • BP 4040 Employee Use of Technology • BP 4113 Assignment • BP 4131 Staff Development • BP 4143.1 Public Notice – Personnel Negotiations • BP 4200 Classified Personnel • BP 4219.42 Exposure Control Plan for Blood-Borne Pathogens • BP 4243.1 Public Notice – Personnel Negotiations The administrative regulation has been updated, but the board policy has not: 42 Personnel Management • AR 4112.42/4212.42/ Drug and Alcohol Testing for School Bus Drivers • AR 4112.61/4212.61/ Employment References • AR 4157.1 Work-Related Injuries • AR 4222 Teacher Aides/Paraprofessionals • AR 4257.1/4357.1 Work-Related Injuries • AR 4300.11 Governing Board/Administrators/ Confidentials Working Relations • AR 4312.61 Employment References Most board policies and administrative regulations were adopted and/or reviewed in 2014, with 158 listed on the district website with a review date in 2014. The second highest group of 101 were reviewed in 2019, with one update in 2017, four updates in 2020 and four updated in 2021. These numbers reflect the district’s slow progression in its efforts to maintain updated, legally compliant policies. Recommendations for Recovery 1. The district should continue to subscribe to CSBA’s policy manual and online policy maintenance services. These services allow the district to update its policy manual as laws affecting schools change. It will also continue to allow public access to the district’s policy manual. However, the district must update its policy manual as updates are sent by CSBA. The HR Department should schedule the backlog of board policies and administrative regulations that need updating and county administrator/board approval including those going back to 2014. 2. The district should regularly update its board policies and administrative regulations to reflect current laws and requirements. 3. The district should adopt board policy for the dismissal/suspension/disciplinary action of classified employees. 4. The district should continue to ensure that board policies and administrative regulations on recruitment and selection are updated to ensure compliance with law related to nondiscrimination in employment. 5. The district should ensure that hiring managers are accountable for the consistent implementation of nondiscrimination policies and regulations. 6. The district should update board policy and the corresponding administrative regulation concurrently to ensure that district procedures align with policy. Personnel Management 43 7. In the interest of ensuring that the appropriate and most recent policies are accessible to those affected, and personnel policy is clearly communicated to employees, outdated poli- cies from 2014 should be regularly updated and should replace the outdated policies on the district website to avoid confusion. 8. The district should continue to send correspondence to all district staff regarding board policy updates. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 44 Personnel Management 1.2 Organization and Planning Professional Standard The personnel function has developed a mission statement and objectives directly related to the LEA’s goals and provides an annual report of activities and services offered during the year. Findings 1. The district’s mission is “to nurture, educate, and graduate students who are self- responsible and self-disciplined; who are critical and creative thinkers; who master the core academic disciplines; and who are advocates for equity and social justice for self and their community.” 2. The HR Department mission is as follows: In support of the Inglewood Unified School District's principles, values, vision, and mission, it is the mission of the Human Resources Department to support the total operation in meeting its goals through its most valuable resource-its PEOPLE. Human Resources is dedicated to promoting, through personalized customer service, the recruitment, selection and retention of highly qualified employees who will effectively serve and meet the needs of our students and the community at large. 3. The department’s vision is “to provide the employee related resources necessary to fulfill the vision of the Inglewood Unified School District to the students, employees, and community by demonstrating core values that include: • Accountability • Integrity • Respect • Responsiveness • Collaboration • Lifelong Learning All geared towards student success and the overall empowerment of district employees.” 4. The department’s mission and vision statements were provided to FCMAT and were easy to access on the district website under the Human Resources Division webpage by clicking on the link titled, Welcome to Human Resources! 5. HR staff indicate that the department meets regularly. 6. There was no evidence that the department developed and is implementing a work plan designed to facilitate the implementation of the department goals. Personnel Management 45 7. Unlike prior review periods, the annual report was not presented to the county administrator/board during a regularly scheduled meeting. This report provides valuable information and data in relation to the personnel function. The Human Resources Division 2021-22 Annual Report was scheduled to be presented to the county administrator/board following FCMAT’s visit. Recommendations for Recovery 1. The district should continue to review the department’s vision and mission statements annually and ensure that they keep pace with changes in district initiatives and continue to support the district’s recovery plan. The mission and vision statements should continue to be clearly and completely stated on the HR Department’s webpage. 2. The district should continue to ensure that the HR Department annually develops measurable goals and objectives that facilitate its mission. The department should also develop a work plan that includes actionable items and measurable progress in implementation of department goals. 3. The district should ensure that the Human Resources Division annual report is updated and annually presented to the county administrator/board. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 5 July 2018 Rating: 7 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 46 Personnel Management 1.3 Organization and Planning Professional Standard The personnel function has an organizational chart, functions chart, and a menu of services that include the names, positions and job functions of all personnel staff. Findings 1. The HR Department organizational chart provided reflects the department’s positions. Staff interviews indicated that the project coordinator positions are temporary and are assigned duties related to COVID-19 safety regulations, HR projects, and other general HR tasks but will soon help implement Business Enhancement System Transformation (BEST). The lines on the organizational chart indicate functional relationships and the supervisory chain of command. The HR Department’s organizational chart is not included on the staff directory page. The HR webpage includes a Division Staff Directory and a Quick Help Menu of Services, which includes contact information for HR staff, but it does not illustrate the reporting structure within the department. The general position title does not provide information regarding the role of the position in the HR Department. 2. The department website has a menu of services that provides information to visitors on whom to call with specific questions, and the menu is located close to the department staff listing. The menu of services that was provided to FCMAT is different from the menu of services on the department website. 3. The HR Department’s online resources are user-friendly and easy to find from the district’s home page by clicking Departments & Services then choosing Human Resources. Visitors to the website have access to the following areas: • Division Staff Directory, Menu of Services, Job Opportunities, Uniform Complaint Procedures, Williams Complaint Procedures, How to Reach Payroll, and Employee COVID-19 Testing • Administrative Handbook – when clicking on the link, visitors, get a message that states, “This site can’t be reached” • Welcome to Human Resources! (HR Goals, Staff Directory and HR Mission and Vision) • Board Policies (link to all board policies) • Personnel Commission (rules, meetings and merit system) – the information is outdated as a staff member who is no longer with the district is listed as the contact for the personnel commission. • Employment Opportunities (job postings, recruitment, classified job descriptions, and internal Request for Transfer form as well as links to the Personnel Commission, Merit System, and board agendas/minutes) Personnel Management 47 • Health and Voluntary Benefits (benefits menu of services, employee benefits portal, medical benefit information, dental coverage information, vision coverage information, employee assistance program and COVID-19 benefits resources) – the benefit plan provided on the website is for the plan year 2020-21 • COVID-19 Leaves of Absence and Information for Employees and Students • Employee Assistance Program and Wellness Resources • Forms and Handbooks (procedural and operational forms for employees and employee handbooks, leave of absence, change of address and various other forms) • Collective Bargaining Agreements and Salary Schedules (ITA Collective Bargaining Agreement, CalPro Collective Bargaining Agreement, Administrative/Confidential Working Regulations, classified and certificated employee salary schedules) – at the time of FCMAT fieldwork, CalPro no longer represented the district’s classified employees, and the district’s website should be updated accordingly. • Leaves of Absence (form and links) • Links to various topics including performance evaluation & assessment forms and attendance reporting through absence management • Merit System information • Professional Development (resources listed including Keenan Safe Schools and productivity & collaboration tools) • Staff Resources (Aeries and Google Mail links) • Absence Management System (instructional materials regarding reporting an absence) • Annual Notifications (Annual Notifications Handbook and Certification Page for 2018-19, 2019-20, 2020-21, and 2021-22) • Annual reports for 2015/2016 through 2020/2021 4. Visitors seeking information about employment are directed to other sites such as NEOGOV or EDJOIN. Recommendations for Recovery 1. The district should ensure the department’s organizational chart is updated when changes occur and included on the department webpage. 48 Personnel Management 2. The district should continue to ensure that the department website is updated regularly with accurate information. Additionally, each applicable HR webpage of the district website should provide a menu of services and whom to call/email with specific questions (e.g., leave approvals, substitutes, recruitment, contract management, credentials). 3. The HR website should be updated any time functions are reorganized or reallocated or when staff members change. Standard Fully Implemented July 2013 Rating: 3 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 8 July 2022 Rating: 8 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 49 1.4 Organization and Planning Professional Standard The personnel function head is a member of the superintendent’s cabinet and participates in decision-making early in the process. Findings 1. The district provided agendas and some notes for the county administrator’s cabinet meetings showing that the interim chief HR officer is a member of the team and participates in decision-making. In many instances, the division update for HR was blank on the Executive Cabinet Agenda. 2. The interim chief HR officer played a key role in decision-making and leadership related to district staffing, position requests, and employee retention. Recommendations for Recovery 1. The district should continue to ensure that the chief HR officer is a member of the county administrator’s cabinet. 2. The chief HR officer should continue to participate in decision-making related to staffing projections, reductions in force, bargaining proposals, nonreelection, professional development planning, employee discipline, and all other matters related to personnel management. 50 Personnel Management Standard Fully Implemented July 2013 Rating: 4 July 2014 Rating: 0 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 9 July 2018 Rating: 10 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 51 1.5 Organization and Planning Professional Standard The personnel function has a data management calendar that lists all the ongoing data activities and responsible parties to ensure meeting critical deadlines on California Longitudinal Pupil Achievement Data System (CALPADS)/California Basic Educational Data System (CBEDS) reporting. The data is reviewed by the appropriate authority prior to certification. Findings 1. The HR Department has implemented a data management calendar for CALPADS and CBEDS, and it is included in the district’s document titled CALPADS & CBEDS Procedures-Human Resources, dated 2021-22. This document includes key tasks and personnel responsible but is missing essential information as it only reflects the Fall 2 submission date information. This document also includes a workflow of information for data flow for reporting purposes. The Information Technology (IT) Department is responsible for leading CALPADS reporting for the district and HR staff provides IT with HR data prior to submission. FCMAT was not provided with evidence of communication between HR and IT. In addition, according to information collected, the 2022/23 CBEDS - Online Reporting Application (ORA) submission that was due October 22, 2022 was certified late on November 10, 2022. 2. Data collection has advanced considerably from the days when manual extraction was necessary to upload data. This practice required a data management calendar. Data is commonly extracted from Human Resource System (HRS) and Aeries through an automated procedure. Interviews with staff indicated and district documentation verified that the district uses the automated method to submit data, which decreases the need for a formal data calendar used in the outdated method. The data flow chart and procedural information created for CALPADS processes is helpful in establishing roles of the HR Department staff and clarity regarding how the information should flow between departments. 3. Data collection procedures have been documented for HR Department staff in working with the IT Department to prepare the necessary data. 4. The HR Department’s annual calendar of essential HR functions has been fully implemented for several years and guides department planning and workflow. The calendar includes a general timeline throughout the year. The HR calendar references that CALPADS is formerly referred to as CBEDS; however, there is still minimal data collected through CBEDS, so this should be added to the HR calendar. The HR Department annual calendar is dated 12-12-22, and the previous recommendation of adding CBEDS to the list of tasks was not implemented. 52 Personnel Management Recommendations for Recovery 1. The district should continue to ensure that the HR Department takes responsibility for HR-related data and functions related to CALPADS and CBEDS, and that this effort is coordinated with the IT Department. The HR and IT departments should continue to work together to fine-tune the work plan that identifies key tasks, personnel responsible, and dates for each task to be completed to ensure timely submission of required state reports. The chief HR officer should continue to review all information and perform a multiyear reasonableness review before certification of CALPADS and CBEDS and transmission of data to the state. 2. The district should ensure the HR Department continues to implement the annual calendar, increasing efficiencies and ensuring compliance with statutory requirements, state and federal employment laws, board policies and administrative regulations, and collective bargaining agreements. Key dates for CALPADS and CBEDS included in the CALPADS processes and procedures document should be added to the HR annual calendar to ensure that coordination of data collection with the sites and other departments is timely. 3. The district should continue to provide evidence of implementation of the protocols and procedures provided in the 2021-22 CALPADS & CBEDS Procedures–Human Resources document. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 7 July 2022 Rating: 8 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 53 3.8 Employee Recruitment/Selection Legal Standard In merit system LEAs, recruitment and selection for classified service are in compliance with the rules of the Personnel Commission and all applicable requirements are followed. (EC 45240- 45320) Findings 1. The district has had a merit system since 2008. When the district came under state receivership in 2012, the then-state administrator suspended the personnel commission based on the requirement in Education Code (EC) 41322(b). In December 2012, classified employees submitted a petition to the board, although its powers reside with the state/ county administrator, requesting termination of this system (per EC 45319-45320). The district conducted an election in March 2013 for classified employees to vote on whether to keep or terminate the merit system, and most chose to retain it. During the last review, the district submitted a document regarding the status of the personnel commission. The document provided that in 2021, the interim chief HR officer requested that the classified union and county administrator select their representatives for the personnel commission, and once the new commissioners were confirmed, they would select the third representative. The process was expected to be completed by January 2022; however, California Professional Employees (CalPro) withdrew from its role as the representative for the classified bargaining unit. The classified bargaining unit elected to replace CalPro with California Teamsters Local 911 on March 4, 2022. 2. For this review period, the district submitted a narrative document with links to evidence related to this and other standards. The narrative document states that the "bargaining units made the decision not to reinstate [the personnel commission]." It also states that the interim chief HR officer was providing training to HR staff on the personnel commission rules and management employees on the classified selection process. No evidence was submitted to indicate that a petition for termination of the merit system according to EC 45319 had been filed or that training on the merit system rules was provided to management employees since the time of the last review. 3. Based on FCMAT’s interviews with staff, the personnel commission rules are consistently applied even though there is no personnel commission. A review of classified management, nonmanagement, and confidential recruitment files indicates that written or performance exams are not occurring. This is not a violation of the personnel commission rules as the rules only indicate the procedures to follow when exams are included in the selection process. The recruitment file review does demonstrate compliance with the personnel commission rules as it relates to oral interviews, eligibility lists, and order of precedence. 54 Personnel Management 4. The district’s website has an active link to a webpage for the personnel commission, and the HR Department has an easily accessible webpage with a direct link to the district’s merit system rules. The personnel commission rules have not been reviewed or updated since originally established in 2008. For example, Section 3.100.2 of the personnel commission rules states that part-time playground positions are exempt from the classified service; however, the related statute, EC 45256, was recently modified to eliminate the exemption for part-time playground positions, placing them into the classified service. In March 2022, the district provided an undated document regarding the status of the personnel commission and notes under Personnel Commission Rules that the department is in the process of reviewing rules for revisions, which will be posted to the website upon completion. At the time of FCMAT’s fieldwork, no such revisions had been posted and evidence of revised personnel commission rules was not provided. 5. For its classified recruitment and selection process, the district uses NEOGOV, an automated applicant tracking system that supports the merit system with automated personnel requisitions, minimum qualification screening, tracking of preemployment skills testing, and other functions of recruitment and selection for classified personnel. Hiring managers can electronically review the applications and resumes for applicable candidates. 6. The classified employment link on the district’s website leads to the NEOGOV website, where the current job openings can be viewed as well as the job descriptions for classified positions in the district. In addition, applicants can submit their employment application through NEOGOV. 7. The district’s Classified Employee Handbook was revised in January 2023. It is included on the new hire checklist for classified employees and is provided during the onboarding process. The handbook includes a comprehensive section regarding the personnel commission rules and regulations, and there is a hyperlink provided to the district website regarding the merit system and personnel commission. Hyperlinks are provided to various other resources, including the district’s board policies and administrative regulations and the collective bargaining agreement. However, the hyperlink to the Classified Employee Handbook on the district’s website is to a March 2020 version. Recommendations for Recovery 1. Until the personnel commission is reestablished, the district should continue to provide staff development on merit system rules and practices for staff in the HR Department and continue to consistently implement the merit system rules for classified personnel. 2. Unless the personnel commission is terminated, the district should assign an HR staff member to oversee updates to the personnel commission policies. The department should begin the process of reviewing and updating the personnel commission rules and regulations as necessary based on revised statutes or practices. The district should continue to include the rules and regulations in the appropriate sections of the Classified Employee Handbook along with a hyperlink to the current version of the document on the HR Department webpage. Personnel Management 55 Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 56 Personnel Management 3.9 Employee Recruitment/Selection Professional Standard The personnel function has a recruitment plan based on an assessment of the LEA’s needs for specific skills, knowledge, and abilities. The LEA has established an adequate recruitment budget. Job applications meet legal and LEA needs. Findings 1. Interviews with principals indicate that, with few exceptions, school sites were fully staffed at the beginning of the 2022-23 school year, a significant improvement over prior years. Additionally, the district’s partnership with Teach for America led to numerous new teacher hires. Principals report that their Teach for America teachers are experiencing success. 2. The district has developed a recruitment plan that includes attendance at job/career fairs. Human Resources maintains an active partnership with California State University (CSU) Dominguez Hills, Concordia, Loyola Marymount University and Teach for America as a teacher pipeline to the teaching profession. The 2022-23 recruitment budget of $75,615 included new employee hiring and induction program incentives. Specifically, the district is providing $1,000 per year per new teacher for three years. Up to six district employees enrolled in an administrative credential program will receive $2,000 in year one, $2,000 in year two, and $1,000 in year three. 3. The recruitment budget and plan funded participation in a virtual job fair at CSU Dominguez Hills and a LACOE induction program job fair. Additionally, the district’s costs related to EDJOIN, NEOGOV, Cooperative Organization for the Development of Employee Selection Procedures and other recruiting systems/technology were included in the recruitment budget as well as other miscellaneous costs such as banners, flyers, and refreshments for the district’s own recruitment fair held in August 2022. 4. The district has developed a Recruitment Workflow Process document specific to the hiring of independent contractors. The four-step process ensures that departments wanting to hire an independent contractor notify the HR Department of the positions assigned duties, a current resume of the identified contractor, and the duration of the assignment. The chief HR officer will review the request and determine eligibility for independent contractor status. According to the three-part test, the HR officer deems the request appropriate under the following criteria: • The worker is free from the control and direction of the district in connection with the performance of the work. • The primary factor bargained for is the work’s result and not the means used to accomplish it. • The worker has an independently established trade, occupation, or business of the same nature as the work performed for the district. Personnel Management 57 Subsequently, Business Services will review the contract to verify insurance and terms. If the independent contractor approval request is denied, the requesting department is notified. For independent contractor requests that are approved, the contractor completes a LiveScan background check and provides a current TB test. The contractor will be approved to begin work once these requirements have been met. While the district provided the independent contractor workflow and two signed independent contractor agreements, there is no evidence that substantiates that an independent contractor determination was made according to the workflow. 5. Documents reviewed indicate that the district continues to use an independent contractor agreement that includes an agreement for consultant services. The document provides the date of services, rate of pay, and other critical information about the nature of the relationship between the district and the contractor. 6. The HR Department has developed detailed selection procedures for recruitment for both hiring managers and site administrators. They include, among other things, screening, interview, rating procedures, and selection. According to the recruitment procedures, HR staff play a limited role in the selection process. Interviews with staff reflect that the selection process is slow and does not keep pace with staffing needs, in addition much of the selection process responsibility has been transferred to the hiring managers and site administration. 7. The district is offering some hiring incentives, but not additional incentives for hard-to-fill teaching positions (e.g., special education). Hiring incentives are effective in recruitment, which would enhance the district’s recruitment profile. • The HR Department updated and added a significant number of job descriptions during the review period. All job descriptions reviewed include an approval date. The positions with approval dates are reflected below: • Administrative assistant (confidential) (county administrator/board approved 12-14-22) • Adult education registration clerk-bilingual (county administrator/board approved 9-14-22) • Benefits & risk management analyst (county administrator/board approved 4-20-22) • College and career specialist (county administrator/board approved 8-24- 22) • Community liaison specialist (county administrator/board approved 8-24-22) • Director of human resources (county administrator/board approved 1-11-23) • Executive director, risk management (county administrator/board approved 11-2-22) 58 Personnel Management • Food services accounting assistant (county administrator/board approved 9-14-22) • Health nutrition assistant, child development center program (county administrator/board approved 9-14-22) • Human resources manager (county administrator/board approved 9-14- 22) 8. Essential duties and responsibilities, and essential functions were listed under the heading “Essential Duties and Responsibilities,” including, in some cases, “other duties as assigned.” Other duties as assigned are considered marginal, which are not essential according to the Equal Employment Opportunity Commission (EEOC), the enforcement agency for the Americans with Disabilities Act. According to the EEOC, job descriptions must identify the essential functions, and employers must make employment decisions based on these. Other functions that are not designated essential are categorized as marginal and are not to be used as a basis for employment decisions, and both essential and marginal functions must be clearly identified in job descriptions. The job descriptions provided were on the district’s standardized templates and formats. Recommendations for Recovery 1. The district should continue to develop an annual recruitment plan and budget that includes attendance at job and career fairs, particularly for teacher recruitment, early in the hiring season. 2. The district should continue to update job descriptions to meet legal requirements and district needs as well as include adoption/revision dates and clearly identify job functions as essential and marginal to comply with the EEOC. 3. The district should continue to use the standardized formatting and templates for all job descriptions. 4. The district should continue to offer hiring incentives and work closely with the Business Services and Educational Services departments in identifying available funding and hiring needs early so that schools are fully staffed by the end of the year for the subsequent school year. 5. The district should continue to develop and support new and existing relationships with local colleges and universities and promote opportunities for credential candidates to student teach in the district. 6. The district should ensure that the recruitment and selection process is timely and keeps pace with staffing needs. Additionally, the HR Department is responsible for the selection process, and should ensure that the responsibility for selection and hiring does not reside with the hiring manager. Personnel Management 59 Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 60 Personnel Management 3.11 Employee Recruitment/Selection Professional Standard Selection procedures are uniformly applied. The LEA systematically initiates and follows up and performs reference checks on all applicants being considered for employment. Findings 1. The HR Department has written procedures on selection and hiring, including paper screening, interview panel procedures, and reference checking. The department uses standard interview questions. A weighted scoring system is used in selecting classified employees. A forced ranking methodology is used for certificated selection. 2. A review of randomly selected recruitment files indicates that interview panel members for classified management and nonmanagement positions routinely sign and date panel materials including rating forms, interview procedures, confidentiality statements, and interview instructions. Certificated management and nonmanagement panel members are equally consistent. However, certificated panel chairs consistently do not initial final rating sheets as required by procedure. 3. The HR Department provides hiring managers with training on conducting reference checks with a focus on willing, cooperative, and honest responses. Classified recruitment files reviewed by FCMAT show that classified reference checks are occurring in every case. However, certificated management and nonmanagement recruitment files did not include evidence of reference checking. Additionally, they did not indicate when offers of employment were made and copies of personnel requisitions were absent. 4. The HR Department employs an HR manager who handles credentialing and is ensuring that all certificated applicants are appropriately credentialed and assigned. 5. The HR Department continues to appropriately maintain recruitment files for each certificated, classified and management recruitment. However, as previously noted, certificated files did not contain copies of reference check forms, personnel requisitions, or any indication of when an offer of employment was made. Based on interviews held during fieldwork, reference checks are occurring, but it is unclear where they are maintained once returned by hiring managers to the HR Department. Recommendations for Recovery 1. The district should continue to provide hiring managers with formal and ongoing annual training in selection procedures, including accessing applications on recruitment websites, screening protocols, reference checking procedures, and nondiscrimination practices. Personnel Management 61 2. The district should continue to ensure that the hiring manager, an HR representative, or other management employee who has been trained in the selection procedures and processes chairs all interview panels. Certificated panel chairs should be held accountable for initialing rating forms. 3. The district should continue to ensure that interview panel members are consistently required to complete the confidentiality statement. The statement should be maintained as part of the recruitment file. Panel chairs should continue to ensure that they brief panel members of their responsibility for maintaining a fair and legally compliant process. 4. Reference checking should continue to be consistently performed when selecting classified management and nonmanagement personnel. Verification of reference checking for certificated management and nonmanagement positions must be filed with the recruitment record and the date upon which an offer of employment was made should be noted. The HR Department should continue with the practice of ensuring reference check forms are signed and returned to the department before offers of employment are made and should ensure that certificated reference checks are appropriately filed. 5. The district should continue to maintain recruitment files separate from employment record/personnel files. Recruitment records should be retained as temporary personnel records, and records should be disposed of according to the district’s retention policy. 6. The district should ensure that all recruitment files include a copy of the personnel requisition. Standard Fully Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 8 July 2018 Rating: 9 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 62 Personnel Management 3.12 Employee Recruitment/Selection Professional Standard The LEA recruits, selects, and monitors principals with strong leadership skills, with a priority on placement of strong leaders at underperforming schools. Findings 1. FCMAT’s review of principal job postings and job descriptions indicates that the duties of these positions were not revised during this review period. 2. The district provided evidence of one principal hire during this review. The position was posted on March 18, 2022 and closed on April 8, 2022. Interviews were not held until June 29, 2022, more than two months after the closing date and after what is traditionally considered prime hiring season for principals. The district’s ability to attract qualified candidates is diminished by the lack of competitive salaries for this position and by late hiring. 3. The district uses a single certificated administrator evaluation form that aligns with guidelines from the CPSEL. While FCMAT requested sample evaluations from 2021-22 and 2022-23 as well as recruitment files related to all principal and assistant principal vacancies filled for 2022-23, only one recruitment file was provided and one personnel record of a longtime principal. The last evaluation filed for the longtime principal was April 2019. 4. The HR Department provided FCMAT with a list of principal evaluations completed during the review period. The list included the name, classification, site, evaluator, evaluation date, a link to the final evaluation, if improvement was needed and if an improvement plan was applicable, date of review by the chief HR officer, and date of entry in HRS. The list included 16 of the district’s 24 principals and assistant principals. Based on this data, all 16 principal and assistant principal evaluations were completed, but only eight of 16 appeared to have been entered into HRS. Additionally, the list provided to FCMAT via Airtable is inconsistent with the position control report, which indicates that only six of the 24 principals and assistant principals have been evaluated since 2015. Recommendations for Recovery 1. Cabinet members or designees who are responsible for the evaluation of principals should continue to use the principal evaluation system based on the CPSEL 2. All forms should include their last date of update to ensure use of the most current form. 3. An annual evaluation should be performed for all principals and assistant principals. An annual listing assigning evaluations should be provided to supervisors responsible for evaluating principals and assistant principals. Members of the executive team responsible for evaluating these individuals should be held accountable to this requirement. Personnel Management 63 4. The district should continue to review and update the evaluation tool and the metrics used to evaluate principals. The district should continue to recruit and hire principals with strong leadership skills and a track record of successfully leading underperforming schools. 5. The district should ensure that all evaluation dates are entered timely and accurately in HRS and Airtable. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 4 July 2016 Rating: 5 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 64 Personnel Management 4.3 Induction and Professional Development Legal Standard The LEA has developed a systematic program for identifying areas of need for in-service training for all employees. The LEA has established a process by which all required notices and in-service training sessions have been performed and documented such as those for child abuse reporting, blood-borne pathogens, drug and alcohol-free workplace, sexual harassment, diversity training, and nondiscrimination. (cf. 4112.9/4212.9/4312.9), GC 11135, EC 56240, EC 44253.7) Findings 1. BPs 4112.9, 4212.9, and 4312.9 provide regulations regarding the district’s responsibility to communicate legal notifications to employees and place a copy of the employee’s signed annual notice in their personnel record. Board policies related to annual notifications in the district were last updated in August 2014, while the CSBA version of the policy was updated in May 2020. 2. The district has trained its managers to assign Keenan Safe Schools online training modules to employees at their sites/departments. Injured employees are assigned Keenan Safe Schools training to improve workplace safety and are required to complete it prior to returning to work. 3. The HR Department continues to provide and document that all employees receive the annually required legal notices including, but not limited to, child abuse reporting, blood- borne pathogens, drug- and alcohol-free workplace, sexual harassment, diversity training, bullying, Integrated Pest Management Plan, safety, use of seclusion and restraint, youth suicide prevention, and nondiscrimination. 4. Additionally, the district also uses Keenan Safe Schools online training for mandatory new hire orientations, which includes understanding sexual harassment, blood-borne pathogens, preventing workplace violence, new employee training, and mandated reporter training. These trainings are to occur prior to the first day of employment. 5. The annual notices continue to require that employees certify that they read and understand these policies. 6. Approximately 87.5% of the personnel files reviewed included evidence that employees received and submitted signed affidavits of having received and understood the required legal notices at the beginning of the 2022-23 school year up from 40% for the 2021-22 school year. A list of all employees provided shows that 93.6% of all employees received and submitted verification of having read and understood the annual notifications. Personnel Management 65 7. Evidence provided shows 93.11% of employees have completed mandated reporter training and 98.21% have completed the required sexual harassment training for 2022-23. Recommendations for Recovery 1. The district should review the most current CSBA policy in relation to annual notifications and update district policies as needed to ensure legal compliance. 2. The district should continue to annually provide to all employees required legal notices, including, but not limited to, the following: • Sexual Harassment and Complaint Policies and Administrative Regulations Legal References: EC 231.5, GC 12950, 2 California Code of Regulations o (CCR) 11023 • Drug- and Alcohol-free Workplace Policies and Administrative Regulations Legal References: GC 8355; 41 United States Code (USC) 8102 o • Use of Pesticide Product, Active Ingredients, Internet Address to Access Information Legal Reference: EC 17612 o • Prohibition of Activities That Are Inconsistent, Incompatible, in Conflict With, or Inimical to Duties; Discipline; Appeal Legal Reference: GC 1126 o • Tobacco-Free Schools Policy and Enforcement Procedures (if the district receives Tobacco-Use Prevention Education funds) Legal Reference: Health and Safety Code 104420 o • AIDS and Hepatitis B Policies and Administrative Regulations Legal References: Health and Safety Code 120875, 120880 o • Status as a Mandated Reporter of Child Abuse, Reporting Obligations, Confidentiality Rights, Copy of Law Legal References: Penal Code 11165.7, 11166.5 o • Availability of Asbestos Management Plan; Any Inspections, Response Actions or Post-Response Actions Planned or in Progress Legal References: Code of Federal Regulations (CFR) 763.84, 763.93 o 66 Personnel Management 3. The district should continue to review and ensure annual notices to employees include board policies or administrative regulations that require them to be provided annually, including, for example, the district’s technology use policy. 4. The district should continue to send annual notices electronically whenever possible and ensure employees certify that they received, reviewed, and understand them. The employee’s signature certifying receipt and knowledge of the notices should continue to be required and included in the personnel record. However, the district should consider changing its board policy to allow for electronic retention of the annual notice affidavits. Additionally, the district should provide follow-up notices to employees who fail to submit the affidavit to ensure 100% compliance. 5. The district should continue to ensure that newly hired employees take the five mandatory online trainings before the first day of employment. 6. The district should continue to keep accurate records of all mandated employee trainings and ensure that the records are either kept in the employee personnel file or electronically stored in a secure file. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 67 4.4 Induction and Professional Development Legal Standard The LEA’s nondiscrimination policy and administrative regulations and the availability of complaint procedures shall be regularly publicized within the LEA and in the community, including posting in all schools and offices including staff lounges and student government meeting rooms. (cf. 4030, cf. 4031, GC 11135) Findings 1. Information about Uniform Complaint Procedures (UCP), including how to file a complaint, can be located on the main landing page of the district HR webpage. The executive director of state and federal programs has been designated as the UCP complaints officer. The complaint form can be accessed by clicking the link for UCP Complaint Form. Users are routed to an electronic form provided by Informed K12. Complainants are then prompted to enter their name and email address to fill out the complaint form, which was updated in March 2023. Forms are available in English and Spanish. The website does not provide information regarding how to access a hard copy complaint form, should the complainant not have access to technology. 2. The HR–Quick Help Menu of Services indicates that the interim HR director is responsible for assisting employees who may be eligible for accommodations under the Americans with Disabilities Act. The district tracks employee accommodations but do not lead the interactive process. The district uses an external company, Shaw HR Consultants, to engage in the interactive process with district employees. It is unclear to what extent, if any, that the HR Department is monitoring accommodation plans to ensure that they are effective and if not, to ensure a follow-up interactive meeting is scheduled. The purpose of this meeting is to determine if another accommodation will be more effective and/or if an accommodation cannot be made. 3. Managers and supervisors are the district’s first line of defense against claims of discrimination. During the prior reporting period, the interim chief HR officer provided training to supervisors and managers in this area. Trainings included a review of legal requirements, the role of managers and supervisors in identifying triggers, conducting interviews with employees who may be eligible employees under the Americans with Disabilities Act, identifying essential functions, and when HR should be contacted in the process, representing a best practice. The district provided copies of principal meeting agendas for the current reporting period. None contained evidence of training in this area. Interviews with staff indicated that training is planned later in the 2022-23 school year. 4. The HR Department’s employee handbooks for certificated and classified employees on its webpage include information on the process for reporting or handling complaints concerning school employees. There was no documentation that verified the interim chief HR officer provided retraining annually to site administrators and department managers on responding to complaints and conducting preliminary investigations. 68 Personnel Management 5. The district’s BP 1312.1-Complaints Concerning District Employees was last updated in January 2013. CSBA provides a version of BP 1312.1 last updated in May 2019. 6. The annual notices provided to employees include instructions and excerpts from board policies and administrative regulations regarding nondiscrimination, reasonable accommodations, and employee complaints. 7. Most of the board policies on nondiscrimination and administrative regulations regarding complaint procedures were updated to the CSBA template in April 2019. However, BP/ AR 4030 related to nondiscrimination identifies the executive director of HR and risk management as the compliance officer despite this responsibility being reassigned to the executive director of state and federal programs. 8. The department monitors the posting of nondiscrimination posters throughout district facilities and conducted the annual review of postings in January 2023. Recommendations for Recovery 1. The district should continue to ensure that nondiscrimination policies are posted in all school offices, staff rooms and student government meeting rooms. 2. The district should update the website and board policies/administrative regulations to accurately reflect the staff member designated to receive and direct UCP complaint investigations anytime the duty is reassigned. 3. Nondiscrimination policies should continue to be reviewed and updated according to CSBA’s policy updates. 4. The HR Department should provide annual training to site administrators and department managers on responding to complaints, conducting preliminary investigations, identifying triggers to the interactive process, conducting interviews with employees, and identifying essential functions. 5. The district should review policies related to complaints concerning employees and update for compliance with the law. 6. The HR Department should continue to ensure procedures and standardized forms for complaints and for the Americans with Disabilities Act interactive process are consistently implemented. Standardized forms for filing complaints should be offered in an alternative hard copy format for complainants who may not have access to technology. Instructions regarding a hard copy version of the complaint form should be included in the complaint procedures. Personnel Management 69 7. The HR Department should annually review accommodation plans and reengage with employees to ensure that accommodations are effective in allowing employees to perform their essential functions. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 4 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 70 Personnel Management 4.5 Induction and Professional Development Professional Standard Initial orientation is provided for all new staff, and orientation materials are provided for new employees in all classifications: substitutes, certificated and classified employees. Findings 1. The HR Department maintains handbooks for the following: • Certificated employees (revised 2022-23) • Classified employees (revised January 2023) • Substitute teachers (revised January 2023) • Classified substitutes (revised January 2023) • Special education instructional assistants (revised January 2023) • Custodial Handbook (revised January 2023) 2. The issuance of the handbooks to new employees is included on the new hire checklist and provided during new employee orientation. All handbooks are available online and are easy to access. The HR annual calendar includes assignments to review and update the employee handbooks each fiscal year by June 30. As evidenced above, the handbooks are current. 3. Beyond providing new employee checklists and copies of related paperwork, the district did not provide examples of orientation materials, which should include, for example, orientation agendas, sign-in sheets and copies of presentations. 4. The department notifies the IT Department of newly hired employees. The IT Department sets up new employees’ email accounts and, if applicable, logins to the district’s student attendance/records management system and substitute/absence management system. Security access to the district’s HRS module is divided between the HR and Business Services departments. Interviews indicate that the information flow between HR and IT regarding new employees is working well due to the Airtable system that HR uses to organize and manage employee data. Recommendations for Recovery 1. The district should continue to review and revise the employee handbooks, notify all employees of any changes, and ensure the most current versions of all the handbooks are available to both internal and external users on the HR Department’s Forms and Handbooks webpage. Personnel Management 71 2. The district should continue to expand and provide job-specific training for new employees, particularly for substitutes in preparation for their first assignment. 3. The district should provide FCMAT with examples of orientation materials, including, orientation agendas, sign-in sheets, and copies of presentations. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 7 July 2018 Rating: 8 July 2019 Rating: 9 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 7 July 2022 Rating: 8 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 72 Personnel Management 4.6 Induction and Professional Development Professional Standard The personnel function has developed an employment checklist to be used for all new employees that includes LEA forms, including acceptable use of technology and state and I-9 federal mandated information. The checklist is signed by the employee and kept on file. Employment Development Department reporting is compiled within 20 days of employment. Findings 1. The HR Department uses new employee checklists that are filed in the personnel file. Revised forms ensure that all legally required notices, such as sexual harassment and complaints, use of pesticides, AIDS/hepatitis B, asbestos management, and the technology use policies (see Standard 4.3) are provided. A signature line for the employee and chief HR officer is included, affirming receipt of all required documents and explanation of all procedures and forms. 2. The HR Department completes the I-9 packet using the current version of Form I-9 as part of the employment process. The I-9 packet of newly hired employees is kept in a separate file as recommended; however, FCMAT’s file review noted that one of 45 employment files reviewed contained a Form I-9. 3. According to the 2010 regulatory changes, I-9 forms can be stored electronically, and the Department of Homeland Security/U.S. Citizenship and Immigration Service recommends that they be kept separate from other employment records. The HR Department has created a separate paper file, and I-9 packets are filed alphabetically. The department is working to electronically store many forms and files maintained in the HR Department and should consider the I-9 packet as one of those files to be maintained electronically. 4. The county office is responsible for reporting new or rehired employees to the Employment Development Department (EDD) within the 20-day limit required by California Unemployment Insurance Code Sections 1088.5 and 1088.8. The district has received confirmation from the county office that an electronic file is sent two times per month to the EDD to ensure compliance with the 20-day requirement. Recommendations for Recovery 1. The new employee checklist should continue to be signed by the employee and chief HR officer and include all legally required notices. Personnel Management 73 2. The HR Department should ensure that the new employee checklist is consistently placed in the employee’s personnel file. 3. Given that Form I-9 has been updated frequently in recent years, the HR Department should continue to use the most current version each time the form is needed. 4. The I-9 form should continue to be omitted from all personnel files and stored electronically. Standard Fully Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 7 July 2018 Rating: 9 July 2019 Rating: 9 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 74 Personnel Management 5.1 Operational Procedures Legal Standard Regulations or agreements covering various types of leaves are fairly administered. (EC 45199, EC 45193, EC 45207, EC 45192, EC 45191) Tracking of employee absences and usage of time off in all categories should be timely and should be reported to payroll for any necessary salary adjustments. Findings 1. Sick and vacation tracking reports provided to FCMAT show that although employee absenteeism is improving, this continues to be area of concern for the district. A sample report of 245 full-time classified employees indicated that 114 used all their sick leave for the 2021-22 school year. Using the same sample group in December of 2022, 73 have used more than half of their sick days for the 2022-23 school year. 2. The recent reorganization of the HR Department positions shifted certificated and classified leave tracking responsibilities to the newly developed administrative analyst position, and a new staff member was hired in July. This created training needs and additional staff support as newly hired HR employees acclimate to their job responsibilities. The interim director of HR provides oversight and support of the leave tracking functions. As an additional layer of administrative and clerical support, the administrative analyst provides support in helping to manage employee leaves by sending leave notification to employees and performing other administrative duties. 3. Supervisors reported that they receive information and responses from HR when they need assistance. Supervisors also report that HR is responsive to long-term absence needs and tries to meet requests for long-term substitutes efficiently. The difficulties in leave management for the district are attributed to the multiple staffing changes in the HR Department, and the frequent changes in the assignment of work in this area. In addition, many employers experienced a decrease in employee attendance as the result of the COVID-19 pandemic, which significantly affects operations but is not within the HR Department’s span of control. The current HR staff has attended leave training this year to gain a shared understanding of employee leaves. 4. HR has continued taking responsibility to handle some of the employee leave functions such as monitoring sick leave usage and contacting employees that reach five consecutive days of absence, sending Family Medical Leave Act (FMLA) notices to trigger the timeline, and calculating the 100 days of extended sick leave and notifying the employee prior to running out of paid leave. Forms and procedures that were previously implemented are ingrained in everyday activities. Staff continue to report coordination between HR, Risk Management, and Payroll to ensure that employees on leave are properly tracked. 5. The absence tracking and reporting function has been modified to an electronic process using Airtable. A review of the district website indicates employees can locate information regarding leaves under the Leaves of Absence link. Once routed to the page, menu options Personnel Management 75 include expired COVID-19 related leaves, medical/disability leaves, FMLA, parental bonding, pregnancy disability, and industrial accident leave. There are also links to various forms, in addition to information about reasonable accommodations, the employee assistance program, industrial injury, and expired COVID-19 related benefits and leave. All employee leaves are tracked through Airtable. The leave notice is initiated by the employee on the website, which then emails the notification to the HR analyst. This will initiate notification to the immediate supervisor, which includes a leave tracking sheet for supervisors to help track the absences. The absence reporting section in employee handbooks requires all employees to call their absences into Frontline, the district’s absence management system. Evidence indicates that employees receive training in this system. Written procedures have been developed for employees and administrators to use Frontline. HR monitors Frontline for any employees who are absent five days or more so that HR can follow up with the employee and request a doctor’s note if needed. Office managers are responsible for monitoring employees reporting absences, and if an absence is not reported, this information is forwarded to the HR analyst for follow up. 6. The district provided documentation of the policies concerning paid overtime procedures. In addition, supervisor training providing instructions for overtime and compensatory time procedures was submitted. Employees are required to submit an Overtime Pre- Authorization Form prior to the overtime being incurred. Document review indicated that a sample of employees had submitted for preauthorization of overtime, then submitted verification that the time was worked. Supervisor signatures indicating approval were noted. FCMAT cannot verify how much overtime is worked compared with the prior year because the district has no central tracking mechanism, and staff reported these hours can be compensated with time off instead of pay. Any overtime hours compensated with time off are not tracked. Practices involving the tracking of overtime would improve if managed as an electronic process (e.g., Airtable). 7. The collective bargaining agreement for classified employees requires accrued vacation to be used within the fiscal year after it is earned, with a maximum carryover of 80 hours, granted on an exception basis. Administrative regulations limit management employees to a maximum carryover of 35 days. Evidence provided shows that at the end of the 2021-22 school year, the district paid 24 employees for excess vacation time to follow the bargaining agreement. The HR website includes a Vacation Use Form and a Vacation Plan Form to allow employees to request vacation as well as plan a yearly vacation schedule. The website does not indicate that vacation request forms are accessible through Airtable, or how HR communicates with supervisors in assisting in the management of vacation. Recommendations for Recovery 1. The district should continue to provide frequent training and reminders for all supervisors on the management of employee leaves and should provide support to supervisors dealing with leave issues to reduce the occurrence and cost of employee leaves. 2. The district should continue to require preapproval of all overtime worked and should also include overtime that is compensated with time off. All overtime worked should be 76 Personnel Management required to be reported to Payroll so that compensatory time off can be centrally tracked and managed since it is a district liability. Management reports should be developed to monitor the amount of overtime worked, whether paid or compensated with time off. 3. The district should continue to require all employees to call the automated substitute calling system when they will be absent and use disciplinary policies for employees who bypass the system. With this approach, absence reporting from the system will include all district employees, and the data can be used to better manage employee leaves and post leave usage to their records. 4. The district should continue to prioritize the implementation of a time and attendance system that allows for employee leave time to be entered at each work site that is validated, posted to employee leave records, and then to the payroll system using Airtable. The district should include management of overtime and compensatory time in an electronic document management system such as Airtable. This will help create accountability measures in addition to improving communication between HR and Payroll. 5. The district should monitor accrued vacation to avoid payouts of excess vacation. 6. The district should prioritize the assignment of leave management and offer training and professional learning to new staff members in the HR Department assigned to the monitoring and management of employee leaves. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 5 July 2017 Rating: 7 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID pandemic July 2021 Rating: 8 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 77 5.4 Operational Procedures Legal Standard Personnel files contents are complete and available for inspection. (EC 44031, LC 1198.5) Findings 1. FCMAT requested that the district provide a personnel report that lists all district employees by employee group (management, classified nonmanagement, certificated nonmanagement) and includes employee ID number, classification, assignment, work location, and date of hire in advance of fieldwork. FCMAT indicated it would randomly select personnel files to be made available for review during fieldwork. The personnel report was not provided. Thirty personnel files, consisting of files for classified and certificated management (five each for a total of 10) and nonmanagement (10 each for a total of 20) employees and 20 recruitment files, were requested by FCMAT on the first day of fieldwork. Few files were immediately available. Department staff had to be reminded numerous times about this request, and ultimately only 45 files were randomly selected and provided to FCMAT for review. These files consistently included the following items: • Teaching credentials (for certificated employees only) • Resumes and applications • Emergency card information • Employment oath signed by the employee 2. Of the personnel files reviewed, 83% contained a file inspection sheet compared to 30% in 2022 and 44% in 2021. All but one of the classified personnel files contained a file inspection sheet. 3. Of the personnel files reviewed, 38% contained an employment history record card compared to 55% during the 2022 review. Employment record cards did not exist in any certificated personnel file. 4. Evidence that employees have completed required sexual harassment and mandated reporter training is maintained electronically, which is a best practice. According to the district’s electronic records, the percentage of employees who have completed the required trainings dropped from 100% in 2022 to 98.21% (sexual harassment) and 93.11% (mandated reporter) for this review (see Standard 4.3). 5. Of the personnel files reviewed, one contained the Form I-9 (see Standard 4.6). 6. Personnel files, health files, workers’ compensation files, Americans with Disabilities Act files, and legal files continue to be stored in the locked records room. All file cabinets in the records room are also locked. 78 Personnel Management 7. Evidence indicated that most annual notice affidavits are completed as required. Evidence provided shows that 93.6% of all employees received and submitted verification of having read and understood the annual notifications. The HR Department is now keeping these files electronically, which represents a best practice; but deviates from BPs 4112.9/4212.9/4312.9 (see Standard 4.3). 8. The Americans with Disabilities Act and the federal Health Insurance Portability and Accountability Act require all medical documents to be filed separately from other personnel or employment records. Of the personnel files reviewed, one contained doctor’s notes and FMLA letters. 9. None of the certificated or classified management files reviewed contained an evaluation completed within the last two years. One classified nonmanagement and two certificated nonmanagement files reviewed contained an evaluation completed within the last two years. 10. Many evaluators interviewed indicate that documents received from HR regarding employee evaluation status came at different times of the year. Specifically, they reported that they received the list of classified employees to be evaluated in the 2022-23 school year in February 2023. 11. The records reviewed included evidence of progressive discipline or the use of performance improvement plans where applicable. 12. Of all files reviewed, 45% contained Social Security numbers (SSNs) or other personally identifiable information as compared to 25% at the time of the last review. Some unredacted SSNs were found on PERS forms and emergency cards. Recommendations for Recovery 1. The employment history record, along with the file inspection sheet, should be the first documents visible to anyone accessing a personnel file. The employment history card should be kept up to date, including all changes in position and/or site assignment. If the entire employment history of all district employees is not maintained electronically, and until all personnel files are electronic, changes in employment history should still be documented in the personnel file. 2. The district should ensure that all personnel files contain an inspection sheet. Except for employees who must access personnel files in the course of their duties, anyone who views a personnel file must sign the inspection sheet. 3. The district should ensure that all employees are evaluated according to local collective bargaining agreements and board policy. Failure to ensure that employees are evaluated makes dismissal difficult even in circumstances where significant or serious misconduct has occurred. At the beginning of each school year, HR staff should provide evaluators with a list of staff to be evaluated during that fiscal year. Personnel Management 79 4. The district should ensure efficacy in the performance management system including: development and implementation of procedures related to the transmission of evaluation forms from site and department managers, timeline for documenting the date of the evaluation in HRS, and the filing of the evaluation in the personnel file. This is equally as important where performance improvement plans are concerned. 5. The district should continue to require employees to complete annual notice affidavits, the mandated reporter training and any required sexual harassment training. Continue to maintain these records electronically. The district should update BPs 4112.9/4212.9/4312.9 to reflect the current practice of collecting and maintaining these records electronically. 6. The district should continue to eliminate any SSNs or other personally identifiable information found in personnel files by reviewing each file accessed for this information and quickly redacting any SSNs found. 7. The I-9 form and all medical documents should continue to be omitted from all personnel files. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 3 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 80 Personnel Management 5.5 Operational Procedures Professional Standard Personnel nonmanagement staff members have individual desk manuals for all of the personnel functions for which they are held responsible, and the HR Department has a process for cross- training. Findings 1. The HR department continues to experience a great deal of staff turnover, although many staff members have been in their current position since the beginning of the 2022-23 school year. Despite this significant change and the short tenure of staff hired for the positions reorganized last year, desk manuals are complete and in the process of being updated. Again this year, the HR Department had undertaken a reorganization with nearly all employees in the department being new to their positions. Desk manuals were a primary source of training as department staff settled into their roles. Staff also report that desk manuals have been key to the success in the cross-training process. Desk manuals reside in Airtable, a cloud-based project management system, and are accessible to all department staff. Evidence suggests that the HR Department uses Airtable consistently. HR Department desk manuals available in Airtable include, but are not limited to, the following: • Recruitment, Selection, and Hiring • Absence Management System • Benefits & Risk Management Department (for the Director and Analyst) • Employee Separation Procedures • HR Generalist • Fit for Duty Assessment/Referrals • Health & Voluntary Benefits Plan Implementation • HRS Data Entry • In addition to housing desk manuals, the HR Department uses Airtable to collaborate interdepartmentally and with school sites. HR uses Airtable to upload and access the following district data: • Location • Employees • Separations • Vacancy/recruitment list • New hires Personnel Management 81 • Job classifications • Essential functions job analysis • Employee credentials • Credentials list • Subjects • Grade levels • Salary schedules • Bargaining units • Staff memos • Employee handbooks 2. HR also used Airtable for the following: • Complaints • Claims management • Concentration of risk • Contract management • Leaves of absence • Retiree benefits • Investigations • Vendor directory • Project management • Recruitment planning • Employee training/professional development • HR annual calendar • Performance evaluations/discipline • Master district calendar • Ergonomics request/management • HR/Risk procedures/desk manuals • Department of Transportation drug/alcohol testing 82 Personnel Management 3. Employee forms and handbooks are available on the district website. Employee handbooks include certificated, substitute teacher, classified, classified substitute, custodial, and special education instructional assistant. All employee handbooks were revised in January 2023. The district provided updated versions of the handbooks to FCMAT; however, at the time of fieldwork, some of the handbooks on the district website have not been updated. 4. There is evidence of cross-training. Staff within the department are clear on their roles and are dedicated to cover one another in the case of an absence. However, no backup for each position has been clearly identified, which along with the number of changes within the department may lead to confusion for those in and outside of the department. 5. The HR Department’s annual calendar continues to be used as a standing agenda item for discussion at the HR staff meetings. Recommendations for Recovery 1. Department staff should continue to review and revise their respective desk manuals. Desk manuals are dynamic documents and should be revised whenever a change is made in a procedure or systems improvement. 2. The district should ensure that data and information in Airtable is current, accurate, and that any confidential information is only accessible to those employees who need to do so to fulfill their assigned job duties. 3. The district should continue to update the HR annual calendar as necessary to keep it up to date. It should continue to be reviewed during each staff meeting to confirm that all staff members understand their role in ensuring these major activities are accomplished. 4. All handbooks should continue to be reviewed annually and updated as needed. The district should make sure the most current version of handbooks is posted on the website. 5. The district should work to clarify the roles and responsibilities of all positions in the HR Department. Backup roles need to be identified, and they should be well communicated to HR staff and to its customers. The district should consider using the Menu of Services document on its website to communicate this information. Additionally, as positions become vacant, the department should be acutely aware of the workload impacts to those individuals who are assigned additional duties, whether permanent or temporary, to determine their reasonableness and provide support wherever possible. Personnel Management 83 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 5 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 84 Personnel Management 5.7 Operational Procedures Professional Standard The personnel function has procedures in place that allow for both personnel and payroll staff to meet regularly to solve problems that develop in the processing of new employees, classification changes, employee promotions, and other issues that may develop. Finding 1. HR, Business Services, and Payroll continue to hold regularly scheduled monthly meetings to coordinate employee issues, provide training, and prepare cross-departmental procedures and forms, which are stored in Airtable. Evidence provided to FCMAT included “rolling” agendas with minutes for monthly meetings. Topics include CalPERS reporting, leaves of absence, payroll corrections, payments for overtime, stipends, and retro pay. Staff members in these departments report that the meetings are systemic and are essential in ensuring that employee situations are handled correctly. Staff report that they each can add topics to the agenda. Additionally, staff report that errors have decreased because of these regular meetings. In between meetings, individual staff members report that they easily communicate with the other departments as needed when situations arise. While HR and Business Services continue to be in different buildings on the district office campus, it has not created barriers to their communication. Their shared use of Airtable has also helped improve their interdepartmental communications. Recommendation for Recovery 1. The district should continue its monthly regularly scheduled meetings between key HR, Business Services, and Payroll staff. As the district continues to fully implement all modules of BEST, these collaborative meetings will be important to the success of the transition. Personnel Management 85 Standard Fully Implemented July 2013 Rating: 3 July 2014 Rating: 0 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 6 July 2018 Rating: 7 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 86 Personnel Management 5.8 Operational Procedures Professional Standard Personnel staff members attend training sessions/workshops to keep abreast of best practices and requirements facing personnel administrators. Findings 1. Evidence of training attended by HR staff during this reporting period is minimal, is not focused on the functions of the HR Department and does not include all department staff. It is important that the district provides high-quality training for all staff members, especially staff that are new to their positions. 2. HR staff were provided with the following trainings: • BEST Financial Module • Attendance and Leave Management Webinar • Keenan Safe Schools including: Annual Notifications, Mandated Reporting, Restraint and Seclusion, Sexual Harassment, and Youth Suicide • Human Resource System • Health Insurance Portability and Accountability Act • Rapid Antigen COVID • Primary Health Platform 3. Verification of attendance at LACOE trainings included the following: • Introduction to Human Resource System • Employee Data Base Maintenance • Intro to Personnel District Benefits • School Financial System Table Maintenance • Public Employees Retirement System Retirement Coding • Prior Year Adjustments Recommendations for Recovery 1. The district should annually identify the training needs of the HR Department staff and the training available to meet those needs. The annual plan should be put in writing and include all HR Department staff. Personnel Management 87 2. The district should provide the HR Department with an annual budget to ensure resources are allocated for staff training and make certain the department is strategic in selecting trainings each year. 3. The HR Department should continue to send a representative to all personnel-related trainings provided by the county office whenever possible. As the district begins the transition into the BEST Human Capital Management (HCM) module, an HR and payroll system for position control, personnel management, and payroll accounting, it is important that staff participate in these training sessions. Standard Fully Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 5 July 2018 Rating: 7 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 9 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 88 Personnel Management 5.10 Operational Procedures Professional Standard Established staffing formulas dictate the assignment of personnel to the various sites and pro- grams. Findings 1. The Certificated Permanent Layoff Timeline document has been updated and implemented for the 2022-23 year. Except for the 2021-22 school year, this has occurred consistently and was successful in ensuring that reductions in certificated service were identified by the end of January so that necessary reductions were made within the statutory timeline, and preliminary layoff notices issued by March 15. Despite this consistent practice, the district has a long practice of reemploying certificated employees as positions were not eliminated in HRS and appeared to be vacant. Personnel requisitions were generated, and staff were reemployed, resulting in perennial overstaffing. HR and Business Services have been working hard to ensure reduced positions are eliminated in HRS. 2. The Business Services, HR, and Educational Services departments continue to work collaboratively to project enrollment and staffing needs and to meet and discuss staffing and any potential layoffs with certificated and classified exclusive representatives. Discussions regarding enrollment projections, staffing needs, and assistance in preparing tentative master schedules at the secondary schools began in early January. 3. In addition to meeting with principals to review staffing and enrollment projections, district leadership met with each site administrator to review current staffing, anticipated attrition due to resignations or retirements, employees on temporary contracts, and any anticipated nonreelections. Changes in the instructional program are considered when identifying staffing needs for subsequent years, and enrollment projections, instructional program changes, and student needs are considered as the master schedules are developed at the district’s secondary schools. This practice has been implemented for six full years and is becoming systematic. 4. The district does not have established staffing ratios other than those listed in the collective bargaining agreements. 5. Staff reported the district is planning to reduce certificated service by 21.0 full-time equivalent (FTE) teaching positions. The first interim teacher ratio calculation provided indicates that although the district continues to be overstaffed, all the positions are funded in the budget. 6. The district provided evidence of the March 9, 2022 county administrator/board-adopted resolutions for anticipated classified reduction in force. The district also provided evidence of the classified seniority list and requests for hearings from employees. Personnel Management 89 Recommendations for Recovery 1. The HR Department should continue to work in collaboration with the Business Services and Educational Services departments, as well as school sites, to develop accurate enrollment projections no later than January of each year. 2. The district should continue to use the Certificated Permanent Layoff Timeline document to ensure that necessary reductions can be made within the statutory timeline, and preliminary layoff notices issued by March 15. 3. The district should create and adopt a Classified Layoff Timeline to ensure that all classified layoff notices are aligned with the new March 15 deadline. 4. The district should continue to monitor enrollment and class sizes after the school year begins to determine if second semester staffing should be adjusted and help ensure that staffing levels remain constant throughout the school year. 5. The district should establish staffing ratios for school sites that include both certificated and classified positions. Once established, the staffing ratios should be reviewed and updated at least annually and provided to site and department administrators. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 90 Personnel Management 5.11 Operational Procedures Professional Standard The LEA has implemented position control processes that incorporate the hiring and placement of all governing board-authorized positions. A reliable position control is a planning tool that has defined standards and formulas for tracking, adding, creating, and deleting positions within the organization to align staffing with budget and payroll systems. Findings 1. The HR department has experienced the turnover of the chief HR officer and the director of HR positions during this year. Staff have been able to maintain the position control procedures; however, inconsistent oversight by the chief HR officer or director has limited the department's capacity to improve procedures and hold other administrators accountable. 2. Board policy and administrative regulations require the board to approve/ratify appointments of new personnel on the recommendation of the superintendent. Since the district has a county administrator and the board is advisory, the county administrator regularly holds public meetings. The district provided evidence that personnel transactions are consistently brought to the meetings and approved/ratified by the county administrator/board. Assignments, reassignments, transfers, demotions, and other personnel actions are governed by collective bargaining agreements for represented employees and by board policy for those who are nonrepresented. 3. BP 3314-Payment For Goods And Services states that: Newly budgeted positions shall be approved at a Board meeting prior to filling the position. Payroll for new employees hired in open positions shall be processed with ratification of the employment occurring at a regularly scheduled Board meeting. 4. This allows changes to the position control database to be based on county administrator/ board approval/ratification. The HR Department has procedures to ensure that all personnel transactions are submitted to the county administrator/board for approval/ ratification. 5. Each request to fill a vacancy is submitted on a personnel action form (PAF). The previous 13-step process, which is now electronic, has been reduced to nine steps. The district provided evidence of Position Control/Requisition Process Training on September 7, 2022. The training slide deck includes detailed workflow including the responsible staff member for each step. 6. In response to concerns that the PAF process continued to take up to a week to process, the district revised the written procedures to include a quarterly review by the HR staff to identify processing delays. The HR manager intervenes if a PAF is not moving through the workflow. Personnel Management 91 7. Evidence provided by HR related to terminated assignments indicates that 132 employees had terminated assignments for the 2021-22 school year and 135 terminated assignments for the 2022-23 school year. 8. The HR Department has not let the obstacles associated with HRS, its position control shortcomings, or the delayed implementation of BEST impede progress. The department continues to use Airtable, a cloud-based spreadsheet-database hybrid, to fill the information access gap. Airtable can sync with other databases and information systems, eliminating the need for data entry that is duplicative. Airtable will also be applicable after the BEST system implementation. 9. The district provided evidence related to the 2021-22 assignment monitoring or credential audit by the county office. The report indicated 155 misassignments of the 2,294 assignments reported; 116 of the misassignments are the result of teacher vacancies. 10. Consistent with the last review, budget controls and preauthorizations continue to be in place for multiple extra-duty, extra-hours, and overtime assignments. Payroll continues to work with principals, directors, office managers, and administrative secretaries to submit requisitions in advance. Payroll understands that it should not pay employees unless an approved position control form has been submitted and is county administrator/ board approved; however, management sometimes still continues to direct staff to make exceptions to get employees paid in a timely manner. The district has a process to monitor the extra-duty assignments of part-time classified employees to ensure that the extra hours do not become part of the employee’s regular assignment by default according to EC 45137. 11. Payroll and HR staff members reported that they meet every two weeks to reconcile position control and to correct errors. The agenda includes errors for specific employees as well as systemic errors that need to be addressed. Certain vacancies in the Special Education Department continue to be filled by contracting with a nonpublic agency (NPA), such as instructional assistants and behavior-related positions. At the time of this review, the district reported continued progress in reducing the use of independent contractors. Additionally, the Special Education Department is closely monitoring caseloads and has closed and/or collapsed an additional four special day classes since the last review. 12. See Standard 7.3 in the Financial Management Section for additional findings related to position control. Recommendations for Recovery 1. The district should continue to implement the electronic personnel requisition process with fidelity, which includes annual training to school site administrators and office managers. The district should ensure that written procedures and workflows are updated, well-communicated, and that users are provided with adequate training and support. Additionally, oversight should ensure that the process is timely and that approvers are held accountable to established approval timelines. 92 Personnel Management 2. The HR Department should continue to ensure that all personnel transactions are submitted to the county administrator/board for approval/ratification. 3. The payroll and HR staff members should continue to meet every two weeks to reconcile position control, accurately identifying and documenting the reason for any termination. 4. The HR Department and Special Education Department should meet regularly and work collaboratively to recruit and retain special education staff and reduce the number of contracted service providers in special education. 5. See Standard 7.3 in the Financial Management Section for additional recommendations related to position control. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 3 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 93 7.1 Use of Technology Professional Standard An online position control system is utilized and is integrated with payroll/financial systems. Findings 1. The district continues to use the LACOE software application HRS for position control, HR, and payroll functions. The district implemented the BEST finance module for fiscal functions, transitioning away from PeopleSoft. The district provided evidence of training given to school site and district office staff to facilitate this implementation. The BEST budget module was live as of January 31, 2022, requiring the district to build its 2022-23 adopted budget in the new financial system prior to July 1, 2022. The budget module will not be fully integrated until the district has implemented the HCM module, an HR and payroll system for position control, personnel management, and payroll accounting. 2. The district needs to continue to clean up data in HRS to ensure that it reflects properly and consistently in position control for budgeting purposes. The interim chief HR officer and HR staff members met regularly with Business Services and school sites to review staffing lists to reconcile and continue the process of validating and cleaning up data errors. Following are some of the ongoing activities used to ensure data integrity and proper information in the budget side of position control: • Position control meetings (HR and Business Services) • Review F-38 (position control) reports • Audit vacancy reports • Data cleanup in HRS • Reducing in-system manipulation, which leads to fewer potential errors • Update school site rosters (Google Docs) 3. Implementation of the HCM module, which will replace HRS, has been delayed. However, the HR Department has not allowed HRS’s limitations, its position control shortcomings or the delayed implementation of BEST, to impede progress. The department is using Airtable, a cloud-based spreadsheet-database hybrid, to fill the information access gap. The district also uses Airtable for tracking employee absences, leaves, industrial injuries, and the return-to-work program. 4. The district has a tentative date for the HCM implementation. The implementation date depends on the accuracy and consistency of the data in HRS. The district needs to be prepared to work closely with LACOE staff during the conversion and verification process. This process is complex and time-consuming. The district will benefit from the regularly scheduled meetings between the business office and HR. 94 Personnel Management 5. For more than five years, the district has used NEOGOV for classified job openings and applicant tracking. HR staff and hiring managers across the district reported that this system works well for the recruitment and selection activities related to classified personnel. The district continues to use EDJOIN for posting certificated openings. NEOGOV is used to complete the onboarding process for certificated and classified personnel. 6. The HRS system drives the payroll system and without an employee being in the HRS system, payroll will not be generated for that employee. Similarly, if incorrect information is contained in HRS, payroll information will be incorrect. Staff reported processing delays frequently occur when positions are not set up in the HRS system prior to the payroll deadline, causing manual payroll advances. Documents provided show that 64 handwritten checks were issued for missed payments in the current review period and varied from zero in one month up to 22 in another month (see Standard 8.2 in the Financial Management section). 7. See Standard 5.11 for additional findings related to position control. Recommendations for Recovery 1. The district should develop a formal training plan for the transition to the BEST HCM module and ensure that all HR staff receive the training and ongoing support needed to ensure a successful implementation. The department should be prepared to manage the time commitment required for this transition while also managing its ongoing workload. 2. The district should continue to use Airtable to improve access to and the functional organization of personnel information and data as well as for tracking employee absences, leaves, industrial injuries, and the return-to-work program. Airtable is being used for some position control functions; however, the district should implement the BEST integrated position control with the payroll system. 3. No matter the system used, position control should be reconciled at each interim reporting period with payroll. 4. See Standard 5.11 for additional recommendations to improve position control. Personnel Management 95 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 4 July 2108 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 96 Personnel Management 7.2 Use of Technology Professional Standard The LEA provides professional development in the appropriate use of technological resources that will assist staff in the performance of their job responsibilities when need exists and when budgets allow such training. (cf. 4131, 4231, 4331) Findings 1. The HR Department website continues to be easily found from the district’s home page. The website includes many resources for the public and for employees, such as a division staff directory, menu of services, procedures and forms, employee handbooks, annual notifications, absence management system, collective bargaining agreements, salary schedules, and personnel commission rules. The menu of services is created in Airtable and provides updated information detailing contact information and quick links for staff to utilize. 2. The HR Department continues to use NEOGOV and other online recruitment and applicant tracking systems (see Standard 7.1) to handle classified and certificated recruitments. Hiring managers have been provided with training on how to access these systems to review applicant paperwork. 3. Staff across the district continue to use online personnel requisitions and the workflow. The system is fully functional, has been reduced in steps (see Standard 5.11), and is cited by users as a significant gain in efficiency and a way to track the progress of requisitions. 4. The HR Department has experienced a significant staff turnover requiring new staff to be trained in the use of technology. HR staff has participated in BEST training as it relates to the HCM module or engaged LACOE staff to create a transition plan. The HR Department continues to use Airtable; all staff members in the department have access to this platform to coordinate staff calendars and meetings, and document and share procedures and desk manuals as they become available, which enhances cross-training. Staff members have incorporated access to Airtable as a regular part of their daily work. 5. HR has continued to use and improve its online onboarding process for new employees, which continues to be of significant benefit. Recommendations for Recovery 1. The district should ensure recurring training, possibly annually, for the existing technologies used by the HR Department staff. This will be especially important as the district begins the process of transitioning from the current HRS to the BEST HCM module. Making sure that the training plan takes into consideration the need for staff to participate in trainings, collaborate, and continue to meet the district’s HR and payroll needs will require planning and coordination. Personnel Management 97 2. As the department continues to implement additional automated functions, such as electronic document storage, and expand the use of Airtable, it should ensure that department staff receive adequate training to implement and maintain these additional systems. 3. The district should review the webpage and update all resources to reflect current information as necessary. Standard Fully Implemented July 2013 Rating: 4 July 2014 Rating: 4 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 6 July 2018 Rating: 8 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 9 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 98 Personnel Management 8.1 Evaluation/Due Process Assistance Legal Standard Clear policies and practices exist for the regular written evaluation and assessment of classified (EC 45113) and certificated employees and managers (EC 44663). Evaluations are done in ac- cordance with negotiated contracts and based on job-specific standards of performance. A clear process exists for providing assistance to certificated and classified employees performing at less- than-satisfactory levels. Findings 1. The district has developed BP/AR 4115, revised February 20, 2019; BP 4215, revised August 4, 2014; and BP 4315, revised February 20, 2019 to provide regulations regarding the district’s practices of employee evaluation. 2. Education Code requires that all certificated employees with permanent status be evaluated at least every other year. Although most staff reported that evaluations were regularly occurring, according to the personnel report provided by the district, no certificated nonmanagement evaluations have been completed since the 2019-2020 school year. There are 57 who have not been evaluated in five or more years (16%) and 129 (37%) have never been evaluated according to this documentation. 3. The classified collective bargaining agreement requires that bargaining unit members with permanent status be evaluated annually. According to the personnel report, only 68 of classified nonmanagement employees (15%) have been evaluated during the reporting period. There are 52 (12%) that have not been evaluated in five or more years and 148 (33%) have never been evaluated. 4. The HR Department provided supervisors with information regarding certificated and classified evaluation timelines and procedures as well as lists of employees to be evaluated. The list identified 351 certificated nonmanagement employees to be evaluated and included their names, job title, school site, and status as permanent, probationary, temporary, or intern. The list did not identify probationary certificated employees as Prob 0, Prob 1, or Prob 2. Because nonreelection decisions must be made by March 15 for Prob 2 employees, the evaluation list should include these designations and clearly communicate that principals notify HR of any nonreelections of Prob 2 employees no later than the end of February so that nonreelection meetings can be held. A best practice is to ensure that the final evaluation be completed prior to these nonreelection meetings. 5. The HR Department is producing a monthly Principal Newsletter. The January and February 2023 editions included a general evaluation reminder and indicated that certificated evaluations were due by May 2023 and classified evaluations by June 2023. Documentation provided indicates that evaluation training was provided to management and supervisory staff. Personnel Management 99 6. The district has not established written procedures for classified employee performance improvement planning but has developed and provided training in the use of standard forms for this purpose. The improvement plan provides the employee with examples of unsatisfactory performance in work quantity, quality, work habits, personal relations, and initiative. The plan does not, however, identify who will monitor the plan and provide support or when progress will be measured. 7. FCMAT requested that the district provide five sample improvement plans developed and monitored during the reporting period. One sample certificated improvement plan was provided and was dated October 17, 2022. The certificated Performance Improvement Plan (PIP) identifies performance that is unsatisfactory as it relates to the California Standards for the Teaching Profession (CSTP) and gives specific examples of the employee’s below standard practice, desired behavior, the date when the employee was expected to demonstrate competency, who would monitor progress, and additional workshops/classes/ curriculum development supports. 8. There is evidence that the district has developed forms for certificated and classified performance improvement planning, and at least one certificated employee received an initial PIP in October 2022. However, there is insufficient evidence to suggest that managers in the district are engaging in performance improvement planning when employees are performing below standards or that such plans are implemented and monitored with fidelity. 9. The HR Department continues to provide support to evaluators who are working with struggling employees. Evaluators report that the chief HR officer is accessible and supportive. Recommendations for Recovery 1. The district should ensure that all employees have been evaluated according to applicable provisions of the Education Code, respective collective bargaining agreements, and board policy. Supervisors should be held accountable for completing these evaluations. The number of employees who have never been evaluated and those not evaluated in more than five years is alarmingly high. Development of a plan to address this standard should be a high priority for the department and the district. 2. Supervisor evaluations should continue to include criteria related to completing certificated and classified evaluations as required by the collective bargaining agreements, ensuring that evaluations are well written, demonstrate competency, and help struggling employees using the district’s standard PIP forms. Additionally, managers should be expected to hold employees accountable to high standards of conduct through progressive discipline measures. 3. The district should continue to ensure that the HR Department annually provides supervisors with a schedule of evaluations based on timelines established in the certificated and classified collective bargaining agreements. Additionally, HR should continue to inform the supervisors of employees who are due to be evaluated in the current school year. The list of evaluations that are due should include the date of the employee’s last evaluation as well as his or her status as a temporary, probationary, or 100 Personnel Management permanent employee. For certificated probationary employees, the list should also identify Prob 0, Prob 1, or Prob 2 status and indicate that recommendations for nonreelection of Prob 2 employees be made to the chief HR officer no later than the end of February or earlier if possible. 4. The district should ensure that managers participate in mandatory training annually on effective supervision and evaluation techniques. 5. The district should develop policies and procedures related to classified employee discipline, written protocols related to nonreelection of certificated staff, probationary release of classified personnel, and the granting of permanency status. 6. The district should continue to enter and track employee status (temporary, probationary, permanent) in the position control system. 7. The district should continue to implement the PIP form and process and offer struggling employees assistance and support. The district should continue to provide annual training related to performance improvement planning, ensure managers are engaging with employees when they are performing below standards, and that PIPs are implemented and monitored with fidelity. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 5 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 101 8.3 Evaluation/Due Process Assistance Professional Standard Management has the ability to evaluate job requirements and match the requirements to the employee’s skills. All classified employees are evaluated on performance at least annually by a management-level employee knowledgeable about their work product. Certificated employees are evaluated as agreed upon in the collective bargaining agreement and California Education Code. The evaluation criteria are clearly communicated and, to the extent possible, measurable. The evaluation includes follow-up on prior performance issues and establishes goals to improve future performance. Findings 1. The current evaluation forms and procedures remain in effect as they have not been updated through the bargaining process. At the time of FCMAT’s fieldwork, the district reported that the evaluation committee in place at the time of the last review was no longer meeting and revised evaluation articles and forms had not been proposed by the Inglewood Teachers Association (ITA), California Teamsters Local 911, or the district. 2. A large number of certificated and classified nonmanagement employees have not been evaluated in accordance with local collective bargaining agreements (see Standard 8.1). Recommendations for Recovery 1. Negotiated changes to the classified evaluation forms should ensure that classified evaluation criteria include job-specific requirements so that managers are expected to evaluate position core competencies and that permanent status is granted only to employees who demonstrate competency. 2. Negotiated changes to the certificated evaluation tool should ensure that criteria are consistent with the CSTP and that the tool ensures that teachers meet minimum competencies when granted permanency status. 3. The district should ensure that all employees have been evaluated according to applicable provisions of the Education Code, respective collective bargaining agreements, and board policy. Supervisors should be held accountable for completing these evaluations. The number of certificated and classified employees who have never been evaluated and those not evaluated in more than five years is alarmingly high. Development of a plan to address this standard should be a high priority for the department and the district. 102 Personnel Management Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 1 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 103 9.5 Employee Services Professional Standard The LEA’s Workers’ Compensation unit is actively involved in providing injured workers with an opportunity to participate in a modified duty/return-to-work program. Updates are regularly provided to the cabinet. Findings 1. Risk management policies, procedures, and forms continue to be accessible on the district’s website including the following: • Employee rights • Company nurse • Industrial injury clinics • Notices to medical providers in English and Spanish • Physician predesignation • Temporary pharmacy card • Links to additional resources such as the Department of Industrial Relations and the Division of Workers’ Compensation • Benefits and risk management analyst contact information 2. During the current reporting period, the district reassigned responsibility for risk management functions to the Business Services Department and hired an executive director of risk management. 3. Written procedures and checklists for managing workers’ compensation cases, and most of the process, including the assignment of modified and/or light duty, continues to be automated. 4. The district continues to implement and refine the procedures manual for industrial injury and illness reporting. All the forms related to reporting continue to be accessible online and include instructions for completing the forms. Policies and procedures for work-related injuries/illnesses are included in employee handbooks, which are accessible from the HR webpage. Online safety training is provided for new employees as well as those on modified duty and is accessible from the Risk Management webpage located under Business Services. 5. The district has a board policy and administrative regulation that provides for transitional assignments to help employees return to work under temporary light duty. The procedures and standardized forms, including a Transitional Return-to-Work Agreement, continue 104 Personnel Management to be implemented with fidelity, are systemic in their use, and a process for annual review is in place. The district’s return-to-work and modified duty program continues to reduce the number of days employees are off work due to industrial injury or illness resulting in continued year-over-year savings. Recommendation for Recovery 1. The district should continue to conduct investigations of workers’ compensation claims, actively engage employees in return-to-work programs, conduct preventive training, provide resources to supervisors and employees, and conduct other best practices in risk management to reduce its costs in the long run. Standard Fully Implemented July 2013 Rating: 1 July 2014 Rating: 2 July 2015 Rating: 1 July 2016 Rating: 2 July 2017 Rating: 5 July 2018 Rating: 7 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 7 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 105 10.2 Employer/Employee Relations Professional Standard The personnel function provides a clearly defined process for bargaining with its employee groups that involves site-level administrators. Findings 1. For this review period, ITA and the district entered into a number of memorandums of understanding, including classroom coverage, teachers on special assignment, Childhood Development Center teacher extra-duty pay, and LCFF TK-3 Grad Span Adjustment (see Standard 14.1 in the Financial Management section for more information). The district and ITA continue to engage in Interest-based Bargaining (IBB) and are working together to solve problems in a collaborative interest-based problem-solving manner. 2. As of March 4, 2022, California Teamsters Local 911 represents classified employees. The district and California Teamsters Local 911 reached agreement on a collective bargaining agreement and at the time of FCMAT’s fieldwork, the agreement had not yet been ratified. The provisions of the existing CalPro agreement, available on the HR Department website, will continue to govern the employment relationship between the district and classified employees until such time as the agreement is ratified. 3. District evidence did not include bargaining session sign-in sheets or other documentation demonstrating that site and department managers participated as members of the management bargaining teams; however interviews indicate that two principals are on the certificated negotiating team. There was no evidence of site-level administrators participating in classified negotiations. Recommendations for Recovery 1. The district should ensure that input from all site administrators and classified department managers is obtained when preparing for labor negotiations each year. This should include feedback on the collective bargaining agreements and proposed changes to the provisions to improve student achievement, management flexibility, and operations. 2. The district should include site administrators and/or department managers who supervise bargaining unit members on the collective bargaining teams as well as a representative from Business Services. 106 Personnel Management Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 3 July 2016 Rating: 5 July 2017 Rating: 7 July 2018 Rating: 7 July 2019 Rating: 8 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 8 July 2022 Rating: 9 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 107 10.3 Employer/Employee Relations Professional Standard The personnel function provides all managers and supervisors (certificated and classified) train- ing in contract management with emphasis on the grievance process and administration. The personnel function provides clearly defined forms and procedures in the handling of grievances for its managers and supervisors. Findings 1. The grievance process is documented in the collective bargaining agreements, which are accessible, along with the forms, to administrators and staff on the HR Department webpage. This page is now easily accessible from the district’s website. 2. One formal classified grievance was filed during the current reporting period and was resolved at Level II. 3. The district and ITA representatives indicated that the IBB process is used in joint committees as well as in regular meetings between management and labor to resolve concerns at the lowest possible level. The district is committed to IBB and is encouraged to pursue similar opportunities with Teamsters. 4. Evidence of training in contract management with an emphasis on the grievance process was provided to FCMAT. Recommendations for Recovery 1. The district should continue its regularly scheduled communication meetings with ITA to foster the ability to resolve issues at the lowest level. 2. The district should continue to ensure training is provided to new managers and refresher training for incumbent managers, with priority given to managing employee leaves, workers’ compensation, evaluation, and grievances. 108 Personnel Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 6 July 2018 Rating: 8 July 2019 Rating: 9 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 6 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 109 10.4 Employer/Employee Relations Professional Standard The personnel function has a process that provides management and the board with information on the impact of bargaining proposals (e.g., fiscal, staffing, management flexibility, student out- comes). Findings 1. On December 14, 2021, the district negotiated a tentative agreement with ITA that was ratified by its members on January 28, 2022. The agreement made numerous changes to various articles and revised the term of the contract to July 1, 2021 through June 30, 2024. The tentative agreement also included the restructure of the certificated salary schedule, retroactive to July 1, 2021, which was equivalent to an overall 6% increase. An additional 4% salary schedule increase was effective July 1, 2022. An AB 1200 disclosure was approved at the February 16, 2022 board meeting. 2. The county office responded to the district’s AB 1200 disclosure on February 15, 2022 stating that the agreement right-sizes the district’s salary schedule and provides equality across salary steps and concluded that per the district’s analysis and as reflected in the disclosure, the district will meet the minimum reserve requirements during the term of the agreement. 3. The district completed an AB 1200 disclosure for the Inglewood Management Association and presented it during the May 11, 2022 board meeting. Per the disclosure board agenda description, the same provisions provided to the ITA, which increased the salary schedules on average by 6% effective July 1, 2021 with an additional 4% increase effective July 1, 2022, will be provided to confidential and management employees. 4. The county office responded to the district’s AB 1200 disclosure on May 9, 2022 stating that the total ongoing increase in compensation is approximately $760,000 and concluded that although the district’s analysis, as reflected in the disclosure, projects it can maintain the minimum reserve requirements during the term of the agreement, it cautioned the district to implement reductions in conformance with its FSP. 5. On May 13, 2022, the district negotiated a tentative agreement with the California Teamsters Local 911, which was ratified by its members on May 19, 2022. Per the disclosure board agenda description, the agreement included the restructure of the classified salary schedule, retroactive to July 1, 2021, which is equivalent to an overall 6% increase with an additional 4% increase effective July 1, 2022. An AB 1200 disclosure was approved during a special board meeting on June 1, 2022. 6. The county office responded to the district’s AB 1200 disclosure on June 1, 2022 stating that the total ongoing increase in compensation is approximately $1.89 million and concluded that although the district’s analysis, as reflected in the disclosure, projects it can maintain the minimum reserve requirement during the term of the agreement, it cautioned the district to implement reductions in conformance with its FSP. 110 Personnel Management 7. Interviews indicate that discussions related to collective bargaining occur at both cabinet and principals’ meetings. 8. See Standards 14.1, 14.2 and 14.3 in the Financial Management section for more information related to collective bargaining. Recommendations for Recovery 1. The district should ensure that Business Services continues to have a representative on both district negotiating teams and that HR and Business Services continue to provide management and the county administrator/board with information on the effects of bargaining proposals, (e.g., fiscal, staffing, management flexibility, and student outcomes). The multiyear impact should continue to be determined and updated for every proposal before it is presented during bargaining. 2. The district should continue to ensure that it timely fulfills its obligations for oversight of any collective bargaining settlements in accordance with Assembly Bill (AB) 1200 and the requirements of Government Code (GC) 3540.2 and EC 42131. 3. Changes in the collective bargaining agreements should continue to be sought to ensure that programs and services can better support student achievement and to restore fiscal solvency. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 4 July 2016 Rating: 5 July 2017 Rating: 6 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Personnel Management 111 112 Personnel Management Table of Personnel Management Ratings Personnel Management 113 114 Personnel Management July July July July July July July July July July July Personnel Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – ORGANIZATION AND PLANNING Omitted The local educational agency per SB 98, (LEA) has clearly defined Section 1.1 0 0 4 4 4 4 5 5 5 5 and clarified roles for board 102 due to and administration relative to COVID-19 recruitment, hiring, evaluation and pandemic. discipline of employees. PROFESSIONAL STANDARD – ORGANIZATION AND PLANNING Omitted The personnel function has per SB 98, developed a mission statement Section 1.2 1 1 3 3 5 7 8 7 7 4 and objectives directly related 102 due to to the LEA’s goals and provides COVID-19 an annual report of activities and pandemic. services offered during the year. PROFESSIONAL STANDARD – Omitted ORGANIZATION AND PLANNING per SB 98, The personnel function has an Section 1.3 organizational chart, functions 3 2 3 3 4 4 6 8 8 8 102 due to chart and a menu of services that COVID-19 include the names, positions and pandemic. job functions of all personnel staff. PROFESSIONAL STANDARD – Omitted ORGANIZATION AND PLANNING per SB 98, The personnel function head is a Section 1.4 member of the superintendent’s 4 0 4 6 9 10 10 10 10 10 102 due to cabinet and participates in COVID-19 decision-making early in the pandemic. process. PROFESSIONAL STANDARD – ORGANIZATION AND PLANNING The personnel function has a data management calendar that lists all the ongoing data activities Omitted and responsible parties to ensure per SB 98, meeting critical deadlines on Section 1.5 2 3 4 6 6 6 7 7 8 4 California Longitudinal Pupil 102 due to Achievement Data System COVID-19 (CALPADS)/California Basic pandemic. Educational Data System (CBEDS) reporting. The data is reviewed by the appropriate authority prior to certification. LEGAL STANDARD – EMPLOYEE RECRUITMENT/ Omitted SELECTION per SB 98, In merit system LEAs, recruitment Section 3.8 and selection for classified service 1 1 2 4 4 4 4 4 4 4 102 due to are in compliance with the rules COVID-19 of the personnel commission and pandemic. all applicable requirements are followed. (EC 45240-45320) PROFESSIONAL STANDARD – EMPLOYEE RECRUITMENT/ SELECTION Omitted The personnel function has a per SB 98, recruitment plan based on an Section 3.9 assessment of the LEA’s needs 0 0 2 4 5 6 5 4 4 5 102 due to for specific skills, knowledge, and COVID-19 abilities. The LEA has established pandemic. an adequate recruitment budget. Job applications meet legal and LEA needs. Personnel Management 115 July July July July July July July July July July July Personnel Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – EMPLOYEE RECRUITMENT/ Omitted SELECTION per SB 98, Selection procedures are Section 3.11 uniformly applied. The LEA 2 2 4 6 8 9 6 7 7 8 102 due to systematically initiates and follows COVID-19 up and performs reference checks pandemic. on all applicants being considered for employment. PROFESSIONAL STANDARD – EMPLOYEE RECRUITMENT/ Omitted SELECTION per SB 98, The LEA recruits, selects, and Section 3.12 1 1 4 5 6 6 6 5 5 5 monitors principals with strong 102 due to leadership skills, with a priority COVID-19 on placement of strong leaders at pandemic. underperforming schools. LEGAL STANDARD – INDUCTION AND PROFESSIONAL DEVELOPMENT The LEA has developed a systematic program for identifying areas of need for in-service Omitted training for all employees. The per SB 98, LEA has established a process Section 4.3 by which all required notices and 1 1 1 4 5 6 6 7 7 7 102 due to in-service training sessions have COVID-19 been performed and documented pandemic. such as those for child abuse reporting, blood-borne pathogens, drug and alcohol-free workplace, sexual harassment, diversity training, and nondiscrimination. (cf. 4112.9/4212.9/4312.9), GC 11135 EC 56240, EC 44253.7) LEGAL STANDARD – INDUCTION AND PROFESSIONAL DEVELOPMENT The LEA’s nondiscrimination Omitted policy and administrative per SB 98, regulations and the availability Section 4.4 of complaint procedures shall 1 1 2 4 5 4 5 4 4 5 102 due to be regularly publicized within COVID-19 the LEA and in the community, pandemic. including posting in all schools and offices including staff lounges and student government meeting rooms. (cf. 4030, cf. 4031, G.C. 11135) PROFESSIONAL STANDARD – INDUCTION AND PROFESSIONAL Omitted DEVELOPMENT per SB 98, Initial orientation is provided for Section 4.5 0 2 2 4 7 8 9 7 8 7 all new staff, and orientation 102 due to materials are provided for new COVID-19 employees in all classifications: pandemic. substitutes, certificated and classified employees. 116 Personnel Management July July July July July July July July July July July Personnel Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – INDUCTION AND PROFESSIONAL DEVELOPMENT The personnel function has developed an employment Omitted checklist to be used for all new per SB 98, employees that includes LEA Section 4.6 2 2 3 4 7 9 9 10 10 10 forms, including acceptable use 102 due to of technology and state and I-9 COVID-19 federal mandated information. pandemic. The checklist is signed by the employee and kept on file. Employment Development Department reporting is compiled within 20 days of employment. LEGAL STANDARD – OPERATIONAL PROCEDURES Regulations or agreements covering various types of leaves Omitted are fairly administered. (EC per SB 98, 45199, EC 45193, EC 45207, EC Section 5.1 3 3 4 5 7 7 7 8 7 7 45192, EC 45191) Tracking of 102 due to employee absences and usage of COVID-19 time off in all categories should be pandemic. timely and should be reported to payroll for any necessary salary adjustments. Omitted LEGAL STANDARD – per SB 98, OPERATIONAL PROCEDURES Section 5.4 Personnel files contents are 1 1 1 3 5 6 6 7 6 6 102 due to complete and available for COVID-19 inspection. (EC 44031, LC 1198.5) pandemic. PROFESSIONAL STANDARD – OPERATIONAL PROCEDURES Omitted Personnel nonmanagement staff per SB 98, members have individual desk Section 5.5 manuals for all of the personnel 2 3 4 5 6 6 6 7 7 7 102 due to functions for which they are COVID-19 held responsible, and the HR pandemic. Department has a process for cross-training. PROFESSIONAL STANDARD – OPERATIONAL PROCEDURES The personnel function has Omitted procedures in place that allow per SB 98, for both personnel and payroll Section 5.7 staff to meet regularly to solve 3 0 3 4 6 7 8 9 10 10 102 due to problems that develop in the COVID-19 processing of new employees, pandemic. classification changes, employee promotions, and other issues that may develop. PROFESSIONAL STANDARD – Omitted OPERATIONAL PROCEDURES per SB 98, Personnel staff members attend Section 5.8 training sessions/workshops to 1 1 2 3 5 7 8 9 9 8 102 due to keep abreast of best practices and COVID-19 requirements facing personnel pandemic. administrators. PROFESSIONAL STANDARD – Omitted OPERATIONAL PROCEDURES per SB 98, Established staffing formulas Section 5.10 3 2 3 3 4 6 6 7 7 7 dictate the assignment of 102 due to personnel to the various sites and COVID-19 programs. pandemic. Personnel Management 117 July July July July July July July July July July July Personnel Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – OPERATIONAL PROCEDURES The LEA has implemented position control processes that incorporate the hiring and Omitted placement of all governing board- per SB 98, authorized positions. A reliable Section 5.11 2 1 3 4 3 5 5 3 4 4 position control is a planning tool 102 due to that has defined standards and COVID-19 formulas for tracking, adding, pandemic. creating, and deleting positions within the organization to align staffing with budget and payroll systems. Omitted PROFESSIONAL STANDARD – per SB 98, USE OF TECHNOLOGY Section 7.1 An online position control system 2 2 4 4 4 5 5 4 4 4 102 due to is utilized and is integrated with COVID-19 payroll/financial systems. pandemic. PROFESSIONAL STANDARD – USE OF TECHNOLOGY The LEA provides professional Omitted development in the appropriate per SB 98, use of technological resources Section 7.2 4 4 4 4 6 8 8 9 9 9 that will assist staff in the 102 due to performance of their job COVID-19 responsibilities when need exists pandemic. and when budgets allow such training. (cf. 4131, 4231, 4331) LEGAL STANDARD – EVALUATION/DUE PROCESS ASSISTANCE Clear policies and practices exist for the regular written evaluation and assessment of classified Omitted (EC 45113) and certificated per SB 98, employees and managers Section 8.1 (EC 44663). Evaluations 0 2 3 4 4 5 5 4 5 3 102 due to are done in accordance with COVID-19 negotiated contracts and based pandemic. on job-specific standards of performance. A clear process exists for providing assistance to certificated and classified employees performing at less- than-satisfactory levels. PROFESSIONAL STANDARD – EVALUATION/DUE PROCESS ASSISTANCE Management has the ability to evaluate job requirements and match the requirements to the employee’s skills. All classified employees are evaluated on performance at least annually by Omitted a management-level employee per SB 98, knowledgeable about their Section 8.3 work product. Certificated 0 0 0 1 3 3 3 3 3 3 102 due to employees are evaluated as COVID-19 agreed upon in the collective pandemic. bargaining agreement and California Education Code. The evaluation criteria are clearly communicated and, to the extent possible, measurable. The evaluation includes follow-up on prior performance issues and establishes goals to improve future performance. 118 Personnel Management July July July July July July July July July July July Personnel Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – EMPLOYEE SERVICES The LEA’s Workers’ Omitted Compensation unit is actively per SB 98, involved in providing injured Section 9.5 1 2 1 2 5 7 8 6 7 9 workers with an opportunity to 102 due to participate in a modified duty/ COVID-19 return-to-work program. Updates pandemic. are regularly provided to the cabinet. PROFESSIONAL STANDARD – EMPLOYER/EMPLOYEE Omitted RELATIONS per SB 98, The personnel function provides Section 10.2 0 0 3 5 7 7 8 8 9 4 a clearly defined process for 102 due to bargaining with its employee COVID-19 groups that involves site-level pandemic. administrators. PROFESSIONAL STANDARD – EMPLOYER/EMPLOYEE RELATIONS The personnel function provides all managers and supervisors Omitted (certificated and classified) per SB 98, training in contract management Section 10.3 1 1 2 3 6 8 9 9 6 7 with emphasis on the grievance 102 due to process and administration. COVID-19 The personnel function provides pandemic. clearly defined forms and procedures in the handling of grievances for its managers and supervisors. PROFESSIONAL STANDARD – EMPLOYER/EMPLOYEE RELATIONS Omitted The personnel function has per SB 98, a process that provides Section 10.4 0 0 4 5 6 7 7 6 7 7 management and the board with 102 due to information on the impact of COVID-19 bargaining proposals, e.g., fiscal, pandemic. staffing, management flexibility, student outcomes. Collective Average Rating 1.46 1.36 2.82 4.00 5.43 6.32 6.60 — 6.57 6.68 6.32 Personnel Management 119 120 Personnel Management Pupil Achievement Pupil Achievement 121 122 Pupil Achievement 1.1 Planning Processes Legal Standard Categorical and compensatory program funds supplement and do not supplant services and materials to be provided by the LEA. (20 USC 6321) Findings 1. The district’s chief business official (CBO) met with principals in fall 2022 regarding the site-budget for 2022-23. The district provided written step-by-step instructions to the principals for line-item budget development that included each site’s respective funding sources. All site expenditure requests are submitted for approval as part of the budget monitoring process. The district holds a monthly budget monitoring meeting for all schools. The budget meetings are held collaboratively with the principal/site designee and Business Services representatives. These meetings sometimes include the CBO, the executive director of state and federal programs, representatives from the Educational Services Department, and others as needed. The district provided evidence of ongoing budget guidance to sites; however, the 2021-22 Budget Development Process For School Sites and Department has not been updated for 2022-23. 2. A review of each school’s School Plan for Student Achievement (SPSA) indicates that the district spends Title I funds to supplement and not supplant services and materials provided by the district. FCMAT found it difficult to connect the schools’ SPSA budgets with their actual site allocations and goals since many SPSAs included a general list of activities and strategies that were not directly linked to budget resource codes or budget lines. In addition, only a few SPSAs reflected that a comprehensive needs assessment had been done before the SPSA development. 3. The California Department of Education (CDE) regularly monitors the district for the appropriate use of federal funds through submitted reports and periodic on-site/ online reviews. The district had 14 noncompliance findings (not all in categorical funds) during its last Federal Program Monitoring (FPM) review. All noncompliant findings were resolved by December 2022. The district developed an online Title I compliance monitoring system and implemented a Title I crate for each site to use to track whether specific Title I tasks were completed by their respective due date. Recommendations for Recovery 1. The district should annually review and update, as needed, a comprehensive site budget procedures manual to guide principals in developing and managing site budgets with timelines and expectations for the use of general and categorical funds. 2. The district should continue to regularly train and support principals and any other site staff involved with budgeting on procedures and monitor compliance. The district should continue to provide training for principals on how to connect SPSA strategies/activities directly to a resource code or budget line. Pupil Achievement 123 3. The district should continue to review site requests for expenditures and carefully monitor them to ensure that categorical and compensatory program funds supplement and do not supplant services and materials to be provided by the district. 4. The district’s Business Services staff and executive director of state and federal programs should continue to regularly meet with principals to monitor the status of categorical funds throughout the year to ensure that they are spent in a timely and appropriate manner. 5. The district should continue to provide each school site with the online Title I compliance crate, ensure that each site is uploading documents, as required, and make certain that the documents reflect a compliant Title I program. 6. The district should ensure that each school that receives Title I funds conducts a comprehensive needs assessment prior to their SPSA development that includes not only surveys, interviews and discussions, but also some sort of verifiable (qualitative or quantitative) data related to the actions included in the plan. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 5 July 2016 Rating: 6 July 2017 Rating: 6 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 124 Pupil Achievement 1.2 Planning Processes Legal Standard Each school has a school site council, comprised of teachers, parents, principal and students, that is actively engaged in school planning. (EC 52050-52075) Findings 1. Board Policy (BP) and Administrative Regulation (AR) 0420, both applicable to this standard, were last updated and approved at the April 2019 board meeting. 2. The district school site council (SSC) timeline provided the sites with guidance to elect officers in August/September each year. All schools met the district deadline for electing SSC officers. 3. Most SSC members have received training on SSC roles and responsibilities. Several dates were offered to meet the team members' availability. Sites are required to submit sign-in sheets or recordings of the meetings to the central office as part of the accountability process. Community liaisons are being trained to provide support to the SSC and recruit parents. The most important part of increasing parental involvement is building positive relationships with the parents. Parent activities give site leadership and staff an opportunity to engage with the parents. 4. The district continues to utilize the accountability measures that have been implemented, which include: 1)The executive director of state and federal programs must preapprove each site's SSC agenda prior to posting, which created oversight to ensure that all items on the agenda are compliant; and, 2) The executive director required each site to conduct four meetings (one for each quarter, at a minimum), which were determined by the principal at each site. 5. The district-required forms must be completed for all SSC compositions, agendas and minutes, to ensure coherence in practice. 6. Each school has a community liaison trained on the Title 1 crate submission process to help ensure that all forms are submitted on time. The executive director reviews the minutes to ensure that the correct information is noted with appropriate detail. All SPSAs are due in June for approval by the county administrator/board at its last meeting of the school year. 7. District leadership has established quarterly dates for sites to turn in all SSC agendas and minutes for review and monitoring, giving the district the ability to validate that the council is composed of the requisite members, meets regularly, evaluates the effectiveness of programs and expenses under its purview, follows proper guidelines for meetings and is actively engaged in decision-making. Formal reviews are periodically conducted throughout the year. Pupil Achievement 125 8. Schools used the district’s SSC membership form to show the composition of their councils. The form outlines the composition requirements for elementary versus secondary SSCs and identifies each member and his or her title as well as the group he or she is representing. The form does not include the date the council was officially formed by electing members and officers, the terms to be served by each member, and it does not provide a signature line for the principal to certify that all the information is correct. 9. The district provided direction regarding SSC composition requirements in its SSC training, and it is also explained in the SSC handbook. Many SSCs had the correct composition of members as required by Education Code (EC) 65000. 10. The district’s SSC handbook contains SSC agenda and minute templates. 11. The district provided SSC trainings addressing SSC bylaws, composition rules, Robert’s Rules of Order, responsibilities of SSC members, a timeline of SSC tasks, and guidance on the SPSA and Title I expenditures. 12. District direction is provided to site leadership, and a timeline of major SSC tasks was included in the SSC training and handbook. Recommendations for Recovery 1. The district should continue to hold site principals accountable to the SSC timeline requirements so there is consistency across the district. 2. The district should modify the SSC composition forms to include the date the council was officially formed by electing members and officers, the terms to be served, and include a signature line for principals to certify that all the information is correct. All sites should use this form. 3. The district should continue to review the composition of each SSC to ensure it has the correct composition as required by EC 65000. 4. The district should provide differentiated assistance by the executive director of state and federal programs to schools that struggle to meet district-established SSC requirements, focusing on those with new site leadership. 5. The district has adopted a standardized format for reporting SSC minutes. Site administrators, with district administrative support, should be held accountable for meeting these requirements. 6. The district should continue to provide annual district training to ensure that SSC members and principals fully understand their roles and are equipped to do their jobs effectively as members. 126 Pupil Achievement 7. The district should continue to provide principals with district support on issues regarding the lack of parental involvement and lagging engagement. Continue site liaison support that allows the SSCs to focus on developing and implementing their SPSAs in alignment with the district’s Local Control and Accountability Plan (LCAP). 8. The district should continue to ensure that SSCs are actively engaged in school planning by the annual adoption of SPSAs in June so that each school has a plan for the upcoming year to spend its allocated funds. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 127 1.4 Planning Processes Professional Standard The LEA’s policies, culture and practices reflect a commitment to implementing systemic reform, innovative leadership, and high expectations to improve student achievement and learning. Findings 1. The Multi-Tiered System of Supports (MTSS) Plan details how the IUSD Instructional Plan 2021-23 will meet the needs of all students and describes, by grade level and content area, the specific supports that should be provided for Tier 1 and Tier 2 academic interventions. Tier 3 academic supports have not yet been defined. The MTSS Plan also includes Tiers 1-3 prescribed interventions for behavior by grade span. 2. In collaboration with the Los Angeles County Office of Education (LACOE) and the California Collaborative for Educational Excellence (CCEE), through the AB 1840 requirement, the district regularly monitors the implementation of its Strategic Plan and actions of its Instructional Priorities 2021-2023 and MTSS Plan. The Systemic Instructional Review (SIR) progress monitoring tool was developed by CCEE and LACOE and is used for quarterly reviews with the district. This tool was designed around the Strategic Plan and is aligned to the district’s LCAP goals and FCMAT standards. The ratings from the most recent report dated November 2022 indicates progress toward implementation in most areas included in the report. 3. Educational partners at all levels (district and site administrators, LACOE, teachers and other staff) continue to report an improved culture and climate throughout the district, with high confidence and trust in the district leadership team’s ability to move the district forward. The district continues to have high turnover in teaching staff, which hinders the entire instructional program. 4. The district administration provided support and resources to principals to help them in aligning their respective SPSA with the goals in the LCAP and the Strategic Plan’s key actions. Resources included a SPSA Checklist, a Plan Template, and a School Site Council SPSA Monitor/Review Template. The Plan Template and SPSA Checklist included components related to the measurable goals for each site, as well as the data for measuring goal attainment. The SPSAs reviewed by FCMAT had measurable, realistic goals based on verifiable data. The district implemented a team approach to reviewing the school site SPSAs that supported the development of coherent plans. 5. The district held regularly scheduled principals’ meetings, which included routine district business, and consistently focused on collaboration, planning and professional learning intended to train principals to serve as instructional leaders. Several additional training opportunities occurred outside the structured meeting time. Some of the topics for principal professional learning included the Cycle of Inquiry (CoI) implementation practices, MTSS including the identification of the core instructional program and 128 Pupil Achievement designated grade-level interventions, the coaching of teachers, and digiCOACH classroom observation tool training with some calibration related to the walk-through elements. 6. The district has continued to contract with the New Leaders organization to provide leadership training and mentoring to principals and the Educational Services management. The New Leaders support includes modules and on-site coaching that focus on leadership theory and practice, with topics that include transformational leadership, planning for instructional excellence and equity to instructional leadership, corrective instruction, intervention, and acceleration. The district reported that the primary goal for its contract with New Leaders is to strengthen the effectiveness of instructional leadership at all schools to fully implement the district’s MTSS Plan. 7. The district targeted full implementation of digiCOACH for the 2022-23 school year; however, consistent use by all district and school leaders varies. The district expects principals to conduct classroom observations using the digiCOACH tool and provide teacher feedback. However, a FCMAT review of the digiCOACH data provided indicates that principals vary in their frequency of use and feedback to teachers using digiCOACH. 8. The district continues to provide a variety of professional learning opportunities for district and site administrators as well as instructional coaches, teachers and site leadership teams. The focus areas for professional learning included: Culturally and Linguistically Responsive Teaching and Learning, MTSS, Dynamic Indicators of Basic Early Literacy Skills (DIBELS), CoI, Elevation program and Positive Behavior Interventions and Supports (PBIS) program. The district administration and LACOE approved the service agreements for professional learning providers in accordance with AB 1840. 9. The district leadership continues to communicate a commitment to high expectations and educational excellence through its equity principle, mission statement, its core beliefs outlined in its Strategic Plan, its MTSS Plan 2021-24 and its Instructional Plan 2021-23 Additionally, it continues to model the process of full implementation of high-leverage strategies through its CoI activities related to graduation rates and transitional kindergarten (TK)-2 literacy. However, based on student assessment data on outcomes, as well as classroom observations, and high school course failure rates, these commitments and high expectations are not yet producing results in most district classrooms. 10. The district continues to use the California Professional Standards for Education Leaders (CPSEL) as the criteria for principal evaluations. The executive directors of elementary and secondary education regularly and rigorously evaluate the principals of the schools to which they have been assigned. In addition to an initial meeting with each principal early in the year to discuss the evaluation process and set goals for the year, both executive directors stated they have monthly meetings with the respective principals assigned to them and complete a midyear review of progress as well as a summative annual evaluation. The district expects executive directors to visit their assigned sites monthly and conduct classroom walk-through observations with the site principal. Pupil Achievement 129 Recommendations for Recovery 1. The district should continue to systematically implement the elements of the Instructional Plan 2021-23 that it has embedded into the digiCOACH classroom observation tool and ensure that principals participate in calibration exercises regarding each element observed. Teachers should be provided with professional learning and a continuum of support to ensure they can demonstrate high effectiveness in implementing each element. The executive directors of elementary and secondary education should conduct frequent site visits and classroom observations with the principals who are assigned to them, modeling the use of digiCOACH and differentiate site support based on observations and progress toward district goals. The district should continue to monitor the digiCOACH data regularly to ensure principals observe teachers and provide effective feedback about the district’s instructional priorities. Executive directors should monitor principals’ consistent instructional leadership strategies, and principals should be held accountable through the district’s evaluation process if they do not adhere to the district’s expectations. 2. The district should continue to systematically introduce and provide professional learning to staff at all levels, as appropriate, regarding the components of its MTSS Plan. Teachers should be provided a continuum of supports to fully implement the plan’s components related to both academic and behavioral interventions, including the implementation of the PBIS program. Supports should include principal observations with effective feedback, coaching support, teacher collaboration by grade level or content area, collaboration with school counselors and others with expertise in specific areas of child behavior and development. 3. The district should continue to provide principals with professional learning and differentiated support through both district-led professional learning and the New Leaders program to ensure they are the instructional leaders at their respective sites. 4. The district should continue to evaluate principals regularly and rigorously according to the schedule and CPSEL standard criteria established by the district, which includes student achievement. The district should also continue to monitor school site behavior, attendance, and academic data monthly and conduct CoI sessions related to district and school site data. 5. The district should continue to make a concerted effort to retain effective site leaders and teachers. The district should also develop a rigorous hiring process for new administrators to ensure that it hires only experienced, proven instructional leaders as principals and provide support and coaching, as needed. 6. The district should continue the collaborative work with CCEE and LACOE to monitor the implementation of the district’s Strategic Plan as well as the Instructional and MTSS plans. Continue to contract for support with external agencies/experts to provide expertise in areas where implementation is stagnant, and the district does not have the capacity. However, when contracting for outside support, the district should identify key personnel to train so that these services could be handled internally in the future whenever possible. 130 Pupil Achievement Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 131 1.5 Planning Processes Professional Standard The LEA has fiscal policies and a fiscal resource allocation plan that are aligned with measurable student achievement outcomes and instructional goals including, but not limited to, the Essential Program Components. (Revised DAIT) Findings 1. The district adopted the IUSD, City Honors and La Tijera 2022-23 LCAPs on June 29, 2022. The district’s LCAP also serves as the Local Educational Agency (LEA) plan. Principals regularly receive information and provide input related to the district’s LCAP as part of the planning process. 2. FCMAT’s review of the district’s LCAP goals and actions found continued alignment between the LCAP and the district’s Strategic Plan, and its 2021-23 Instructional Plan. In addition, the schools’ SPSA goals were aligned to the district’s LCAP actions and goals for improved student achievement. The district uses the updated CDE template for SPSAs. 3. Site principals reported attending regular meetings with staff in the Business Services Department to monitor site budgets during 2022-23. Monthly site budget meeting agendas addressed site budget questions, a resource-by-resource review, a review of the supplemental, concentration and Title I allocations, and a review of staffing changes (transfers, resignations, and new hires). Additionally, sites reported having met with the executive director of state and federal programs to discuss their individual site budgets. Principals reported receiving support with developing their site budget and SPSA. Principals continue to use district resources including a SPSA Checklist, a Plan Template, and a School Site Council SPSA Monitor/Review Template. The Plan Template and SPSA Checklist included components related to the measurable goals for each site as well as the data for measuring goal attainment. Recommendations for Recovery 1. The district should continue to involve principals in the LCAP planning process. 2. The district should continue to ensure school site budget development and management that facilitates program implementation to support the goals in the LCAP, the Strategic Plan and SPSAs. This will maximize benefits for students. 3. The district should ensure that the executive director of state and federal programs, Business Services Department budget representatives and site principals continue to meet regularly throughout the year as a system for reviewing the site budgets and helping to make decisions that support the LCAP, Strategic Plan and SPSAs. 132 Pupil Achievement 4. The district should continue to periodically monitor SSC minutes throughout the year for site-level budget decisions and evaluation of program effectiveness, ensuring that adjustments are made as needed. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 133 1.6 Planning Processes Professional Standard The LEA has policies to fully implement the State Board of Education-adopted Essential Program Components for Instructional Success. These include implementation of instructional materials, intervention programs, aligned assessments, appropriate use of pacing and instructional time, and alignment of categorical programs and instructional support. Findings 1. The district has multiple board policies that speak expressly to this standard such as BP 6161.1 and 6161.11. 2. The district continued to implement its Strategic Plan for 2018-23. In addition, the district developed plans that provide the scope and detail for how it will achieve its Strategic Plan goals. These additional plans are coherent and include the MTSS Plan, the English Learner Plan, and the Instructional Plan 2021-23. All the SBE-adopted Essential Program Components are included under the comprehensive structure of the Strategic Plan. 3. The district provides standards-aligned, board-adopted curriculum in English language arts (ELA), mathematics, science, and social science to its teachers. High school curricular offerings in some A-G requirements, such as visual and performing arts and Career Technical Education (CTE) pathways, are limited due to the small size of the district’s high schools; however, partnerships with El Camino College and Southern California Regional Occupational Center have expanded opportunities. During FCMAT classroom visits, team members observed teachers and students using the district-adopted instructional materials. 4. The district created and implemented a comprehensive assessment calendar in collaboration with teachers and principals. This calendar includes district benchmark assessments administered three times during the year (i-Ready, DIBELS, and Achieve 3000, depending on grade level and content areas). Additionally, the district provided assessment options to be selected by school sites and/or grade level/content areas that would be used for formative assessments at the classroom level. The district provided evidence of benchmark assessment data reviews for the beginning of the year and midyear assessments. FCMAT found improved completion rates for the defined benchmark assessments, which includes CoIs, with some variance across the district. 5. The district negotiated banked time and now provides teachers with collaboration time on a Tuesday afternoon early student release schedule. There is a planned schedule/calendar of topics for the use of this collaboration time. 6. The district does not provide systematic intervention during the instructional day as recommended by the California State Frameworks in mathematics and ELA and as stated in its LCAP. The district continued to contract with Hey Tutors to provide pull-out or push-in support for identified students during the day and provide some after-school 134 Pupil Achievement tutoring. The district funds accelerated learning teachers (ALTs) at all elementary sites to provide intervention and support for staff and students. High school students in need of credit recovery have the Apex program available. 7. Evidence of Tier 1 classroom interventions varied between sites and classrooms. Lesson plans reviewed throughout the district were inconsistent in the degree of planning with intentionality to include effective instructional strategies, rigor, and Tier 1 interventions into the lessons. The i-Ready Program is primarily used throughout the district for Tier 2 intervention for grades K-8 and Achieve 3000 for grades 9-12. The district plan for systematic Tier 2 implementation is in early levels of implementation. The district does not have an articulated plan for its Tier 3 intervention, but it is scheduled to begin work on it during the spring semester of 2023. 8. The district has not adopted an SBE-approved intensive-level reading intervention program, as described in the California ELA Framework, for grade 4-8 students who are two or more years behind grade level. Recommendations for Recovery 1. The district should continue to make the components of its Instructional Plan 2021-23 a priority for implementation throughout the district by: • Ensuring that teachers and principals receive a continuum of professional learning and supports that lead to full implementation (research recommends at least 90% of teachers using the components at least 90% of the time). • Holding principals accountable for conducting classroom observations as directed by the district. • Conducting collaborative classroom walks with the principal and executive directors of elementary and secondary education and providing differentiated coaching support to address any instructional deficiencies at the school site. • Developing written guidelines and expectations for teacher lesson plans. These guidelines should be aligned with the district’s instructional priorities and should help ensure that teachers build lessons with intentionality to include high levels of depth-of-knowledge (DOK) questions, student collaboration, and effective Tier 1 strategies such as checking for understanding throughout the instructional process. • Providing a continuum of supports to grade-level/content-area teacher teams to conduct lesson studies to assess (using the CoI process) the rigor of planned/delivered lessons and student assignments in relation to state standards and adjust them accordingly. 2. The district should implement and monitor its plan for MTSS, for both academic and behavior issues by: Pupil Achievement 135 • Clearly defining Tier 2 and Tier 3 academic interventions. • Monitoring the effective use and implementation of the i-Ready program to ensure that it is strictly used as designed. This includes ensuring that all students in need of Tier 2 intervention are provided the recommended time every week and that all components of the program are used with teacher/aide supervision and guidance. • Providing training to teachers in the district’s adopted ELA and mathematics curriculum materials so they can effectively use all components of the material to provide Tier 1 interventions in the regular instructional program. • Ensuring all teachers use curriculum-embedded formative assessments during the instructional process to appropriately reteach as needed based on student understanding. • Holding principals accountable for ensuring that the appropriate pacing of instruction and the staff administration of assessments are occurring as directed by the district and that 95% of students participate in each assessment. • Providing teachers and principals with differentiated ongoing training and support in using data from assessments to monitor, adjust, and individualize instruction consistent with the Common Core State Standards (CCSS) and the MTSS process. • Providing systematic training to teacher teams on the CoI process. • Supporting and monitoring collaboration time to ensure that teams use these practices as they work to improve their instruction to meet student needs. 3. The district should adopt an SBE-approved intensive-level reading intervention program, as described in the California ELA Framework, for grade 4-8 students who are two or more years behind grade level. 136 Pupil Achievement Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 5 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 137 1.8 Planning Processes Professional Standard The LEA provides and supports the use of information systems and technology to manage student data, and provides professional development to site staff on effectively analyzing and applying data to improve student learning and achievement. (DAIT) Findings 1. The district continues to have Information Technology (IT) split between departments. The executive director of IT reports to the CBO and oversees a database administrator and a director of IT, and the director of educational technology reports to the chief academic officer (CAO). The executive director participates in Educational Services meetings and attends principals’ meetings. This provides opportunities for frequent communication and collaboration about the management and dissemination of student data. The executive director continues to work to strengthen the district technology infrastructure and information systems to provide accurate and timely student data to the LEA. 2. The district advisor responsible for assessment and data effectively provides guidance, resources, and support to sites, resulting in more consistent administration of formative assessments. 3. The district assessment calendar continues to require the use of technology-based i-Ready assessments, California Assessment of Student Performance and Progress (CAASPP) summative assessments, English Language Proficiency Assessments for California (ELPAC), DIBELS and Achieve 3000. Professional learning has been provided to principals and teachers on access to the systems for these technology-based assessments. The revised CoI approach provides a range of technology-based data reports, tools, and resources for analysis and instructional planning. 4. The district Instructional Plan, Strategic Plan, and LCAP include goals and action steps related to implementation of a districtwide, data-based CoI process for data analysis and action planning. A common data analysis process and template have been selected for districtwide use. Evidence indicates professional learning experiences for the CoI process have been primarily focused on the procedural elements in a workshop format. Schools continue to need training on the use of the CoI process to develop action steps that influence practice within the classroom instruction. Recommendations for Recovery 1. The district should continue to monitor the management and accuracy of student information through collaboration between the district IT staff and the Educational Services team. 2. The district should continue to support the district advisor for assessment and instructional technology to implement the educational duties related to state and locally 138 Pupil Achievement required assessments. Continue to provide professional learning as appropriate to ensure the use of best practices for interpreting, analyzing, and presenting assessment data accurately and in an understandable format. 3. The district should accelerate efforts to address the goals and action steps in all district plans related to the use of data to increase student achievement, including those requiring additional professional learning. 4. The district should continue to frequently and explicitly communicate district expectations to principals and teachers concerning the analysis of student achievement data and the use of this information in guiding instructional planning and the delivery of high-quality, data-driven instruction. 5. The district should continue to refine the common data analysis process and template for use at all school sites by grade level/department teams. Continue and expand opportunities for hands-on guided practice on the effective use of the data analysis process included in the district-provided template. In the professional learning activities, emphasize depth of implementation, including the identification of specific, measurable instructional goals and action steps to address student needs determined through the analysis of student performance data. Regularly monitor the quality of implementation of the CoI process and work products generated through the process at all levels of the system. 6. The district should hold principals and teachers accountable for using the assessment data provided by the district to identify individual student learning needs targeted to specific content standards or clusters of standards and for developing and implementing measurable instructional goals and action steps to address those needs. Site principals should monitor the implementation and progress-monitoring components of instructional action plans, with support from the executive directors of elementary and secondary education. 7. The district should continue to provide principals with ongoing professional learning opportunities that strengthen their ability to use short-cycle formative assessment data, as well as district and state summative assessment data, to inform instructional and curricular decisions at the school sites. Include specific strategies/techniques for coaching teachers in the analysis of student achievement data that results in the development and implementation of explicit, measurable instructional goals and action steps to design and deliver high-quality, data-driven instruction. 8. The district should continue to provide ongoing professional learning for teachers and leaders to increase the depth of their capacity to analyze the variety of reports available from district-required assessments and to use the tools and resources provided in the assessment programs to develop and implement explicit, measurable instructional goals and action steps to address student learning needs. Pupil Achievement 139 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 140 Pupil Achievement 1.9 Planning Processes Professional Standard The LEA holds teachers, site administrators, and LEA personnel accountable for student achieve- ment through evaluations and professional development. Findings 1. Principals reported that they conduct their respective teacher and classified staff evaluations as directed by the district’s policies. Teachers are evaluated based on the California Standards for the Teaching Profession (CSTP). In 2021-22, the district convened a certificated evaluation development committee to revise the evaluation process and documents that are used for teacher evaluation. This committee did not meet during this review period due to a vacancy in Human Resources (HR) leadership. 2. Principals and certificated managers continue to be evaluated based on the CPSEL standards. 3. Article XVI-Evaluation Procedure of the ITA contract includes verbiage such as the following: … the principle objective in evaluation is to improve the quality of education in the District,” and also states that “… (student assessment) data is to be considered and used solely as a formative assessment tool to inform and shape adjustments to the instructional strategies… However, BP 4115 states the following: The Superintendent or designee shall assess the performance of certificated in- structional staff as it reasonably relates to the following criteria: (EC 44662) Students’ progress toward meeting district standards of expected achievement for their grade level in each area of study and, if applicable, towards the state-adopted content standards as measured by state-adopted criterion-referenced assessments. There continues to be a discrepancy between the district’s BP 4115 and ITA contract Article XVI in the use of student assessment data in the evaluation process of certificated staff. In addition, it is unclear how any assessment data are used in the formative assessment process by teachers. A review of the certificated evaluation form as well as the Certificated Employee Handbook indicates that neither document included any reference to student achievement or student learning. 4. The district uses the digiCOACH classroom observation tool to create districtwide observation standards aligned to its Instructional Priorities. The digiCOACH usage report indicates that its use by principals continues to vary. In addition, the principal feedback to teachers reviewed by FCMAT varied in effectiveness. Pupil Achievement 141 5. Principals have participated in several professional learning opportunities throughout the 2022-23 school year. Some of the district’s initiatives for the year, such as MTSS and the Instructional Priorities, were shared with principals during staff meetings and other trainings with the expectation that they would share the information with and train their staff in those areas. The district provided professional learning for paraprofessionals directed at their needs to better support classroom teachers and students. The district developed a partnership with CSU Dominguez Hills to support a cohort of instructional aides. Those involved in the program reported that it was worthwhile and informative, resulting in increased engagement during the sessions, improved morale, and effectiveness. Recommendations for Recovery 1. The district should continue to ensure a tone of accountability and high expectations for all staff as evidenced by: a. Maintaining and monitoring data from the observation platform (digiCOACH) reports as it incrementally implements current and additional instructional priori- ties. b. Reviewing walk-through data, feedback provision, and outcomes collaboratively between district executive directors and principals monthly to gauge the degree of implementation of effective first instruction and to provide differentiated support to instructional staff. 2. The district should continue to ensure that principals are regularly and rigorously evaluated according to the schedule and criteria established by the district as evidenced by: a. Focused use of the CPSEL to support each principal’s instructional leadership skills for improving instruction and student achievement. b. Holding a minimum of monthly school site visits by the elementary and secondary executive directors with their assigned principals to collaboratively conduct class- room observations and hold quarterly conferences with them to set and review metrics and progress and provide guidance and assistance, as needed. 3. The district should ensure that all district administrators, including executive directors, have performance evaluations that include specific goals or growth targets related to the LCAP and/or the current year’s Instructional Plan and are framed around instructional leadership. 4. The district should actively engage in restructuring the teacher evaluation process to focus more clearly on the CSTP with a focus on explicit connections between teaching and learning. 5. The district, in collaboration with the bargaining units and management organization, should develop and implement systems of support for teachers that include referrals by principals for instructional coach support, in addition to teacher request. This will allow 142 Pupil Achievement principals to have a full range of means to support teachers and increase their effectiveness to improve student achievement using the formative evaluation process. 6. The district should continue to collaborate with educational partner groups in the development of a professional learning plan for 2023-24 that is focused on measurable goals and objectives related to the MTSS and Instructional Priorities plans. The plan should outline professional learning that demonstrates coherence throughout the system and considers all stakeholders. Monitoring and accountability measures should be included that result in observable improvement at the classroom level. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 143 2.1 Curriculum Legal Standard The LEA provides and fully implements SBE-adopted and standards-based (or aligned for sec- ondary) instructional textbooks and materials for all students, including intervention in reading/ language arts and mathematics, and support for students failing to demonstrate proficiency in history, social studies, and science. (EC 60119, DAIT) Findings 1. As noted in Standard 1.6, the district provides SBE-adopted instructional materials for grades TK-8 and standards-aligned curriculum for grades 9-12 in all content areas related to EC 60119, including English language development (ELD). The district continues to lack SBE-adopted materials in ELA for students in grades 4-8 in need of intensive intervention as defined by the California State ELA Framework for students who perform more than two years below grade level. The district’s MTSS Plan outlines district-approved Tier 1 and some Tier 2 curricular and program interventions. 2. FCMAT observed classrooms at every school in the district during its review. In general, school sites were orderly, and classrooms had the district-approved instructional materials to meet the needs of students, including English language learners (ELLs) and students with disabilities (SWDs) except for an SBE-adopted ELA curriculum for grade 4-8 students in need of intensive intervention. Some classrooms had supplementary materials that were not approved by the district. 3. While the district’s MTSS Plan includes academic interventions for Tier 1, as well as some district-approved interventions for Tier 2 by grade level/content areas, Tier 3 is not yet developed. The district is implementing the plan, and all teachers have been provided with professional learning on it. However, the use of Tier 1 instructional interventions was observed to be inconsistent throughout the district. Tier 2 interventions primarily used include i-Ready, Achieve 3000, and there are plans to implement Imagine Learning for ELLs in fall 2023. The high schools use the Apex Program for credit recovery. Saturday school began in winter 2023 with limited student participation. 4. The district contracted with the 95% Group to provide professional learning and support to sites in literacy instruction (The Science of Reading for grades K-5 and Reading Apprenticeship for grades 9-12). This action is in direct alignment with the district’s instructional priority #2 (literacy performance). 144 Pupil Achievement Recommendations for Recovery 1. The district should intensify site monitoring to ensure effective, rigorous first instruction using district-adopted curriculum and identified instructional strategies and that it occurs daily throughout the district. 2. The district should identify and clearly communicate supplemental materials that are acceptable for use in classrooms. 3. The district should systematically implement its MTSS Plan. Implementation should include: • Provision of a continuum of professional learning for teachers that ranges from holding workshops to coaching, observing other teachers, coplanning/coteaching, and teacher grade-`level or content-area collaborating. • Selection, adoption, and implementation of intervention curriculum (SBE-adopted Program IV) materials for grades 4-8 students who require intensive intervention in ELA. • Selection, adoption and implementation of mathematics intervention materials in accordance with the California Mathematics Framework recommendations. In addition, the district should ensure all sites incorporate appropriate intervention time during the regular instructional day based on California State Framework recommendations. • Systematically developing the professional learning community (PLC) process during collaboration time for teachers to identify and develop lessons grounded in the focus standards and the calibration of student work products. • Monitoring the effectiveness of the site intervention programs based on student achievement data and determining if the programs and strategies used support the goals of the district to improve student achievement. 4. The district should evaluate the effectiveness of implementing literacy professional learning and its impact on student achievement. The district should research evidence- based Tier I supplementary literacy programs and strategies. Pupil Achievement 145 Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating 3 July 2018 Rating: 3 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 146 Pupil Achievement 2.3 Curriculum Professional Standard The LEA has planned, adopted and implemented an academic program based on California con- tent standards, frameworks, and SBE-adopted/aligned materials, and articulated it to curriculum, instruction, and assessments in the LEA plan. (DAIT) Findings 1. The district’s most recent county administrator/board-approved LCAP also serves as the LEA plan. FCMAT’s review of the district’s LCAP goals and actions found alignment between the LCAP and the district’s Strategic Plan, and its 2021-23 Instructional Plan. In addition, the schools’ SPSA goals were aligned to the district’s LCAP actions and goals for improved student achievement. The district is implementing most elements of the instructional components of the Strategic Plan. 2. There continues to be a lack of evidence of the use of the 2020-21 ELA and mathematics pacing/instructional guides. However, based on interviews with staff, the district made a concerted effort to strategically design an assessment system that could improve student learning if fully implemented by teachers throughout the district. The district, in collaboration with its teachers and principals, created and implemented an Assessment Plan for 2022-23. This plan aligns with the district’s MTSS Plan and includes universal screening for Tier 1 students three times a year based on benchmark assessments related to either DIBELS, i-Ready or Achieve 3000, depending on the grade span of students. The Assessment Plan includes a schedule for the administration of benchmarks and district- approved formative assessment options. Schools or grade spans or content areas can select from these options to use for the CoI process during teacher collaboration time. 3. The district set a goal of 95% participation rate for assessment of students, and has continually monitored assessment completion data, resulting in all schools achieving close to the 95% goal. In addition, FCMAT found that samples of the district’s CoI process related to achievement data did not include disaggregated data for ELLs or SWDs, which are two of the district’s high priority groups based on its LCAP. The district’s ELA program, including curriculum and instruction, is not aligned with the California Frameworks in ELA regarding providing an intensive intervention program for grade 4-8 students as noted in Standard 2.1. 4. As noted in its Strategic Plan, effective first instruction continues to be a district focus. However, recent district benchmark assessment data, as well as the high course failure rate of high school students from the first semester of 2022-23 indicate that a high percentage of students need more Tier 1 strategic support, in addition to Tier 2 and 3 interventions. Pupil Achievement 147 Recommendations for Recovery 1. The district should fully align its LCAP with the needs of its students. As previously noted in Standard 2.1, the district should implement an intensive intervention for ELA and mathematics as detailed in the recommendations in the California Frameworks. 2. The district should leverage the use of the PLC structure to support and guide effective first instruction to support success for all students. 3. The district should continue to monitor the effectiveness of the Assessment Plan 2022-23 and revise the plan as needed. To achieve a 95% completion rate in assessment, the district should: • Analyze and review the current assessment calendar to ensure alignment with instruction. • Monitor the completion rates of assessments as necessary for 2023-24. The executive directors of elementary and secondary education should hold their respective principals accountable for this process. • Along with school sites, disaggregate data for student populations. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 148 Pupil Achievement 2.4 Curriculum Professional Standard The LEA has developed and implemented common assessments to assess strengths and weak- nesses of the instructional program to guide curriculum development. Findings 1. The district Instructional Plan, Strategic Plan and LCAP include goals and action steps related to the implementation of common assessments to monitor student outcomes and assess the strengths and weaknesses of the instructional program to guide curriculum development. 2. A districtwide system of required common assessments is in place. The district developed and published a 2022-23 assessment schedule that communicates clear expectations regarding which common assessments are required to be administered at each grade level/ content area and the timeline for that administration. I-Ready, DIBELS (K-2) and Achieve 3000 assessments are expected to be administered three times during the academic year as described in the assessment schedule. The district goal is for 95% of students at each grade level/content area to complete the required assessments. 3. The district continues to communicate the purpose of the assessments to improve instruction and to provide feedback to staff and students; however, it continues to have variations in how the communication is implemented. 4. District-provided data indicate completion rates for required assessments have improved and are consistently within the 90-95% completion rate. 5. Data summaries for required district assessments were presented at Educational Services and principals’ meetings multiple times throughout the school year. Summary presentations did not always include disaggregated data for student groups, as some could not be viewed by demographics or subgroups. 6. The district continues to struggle to establish measurable action steps grounded in CoI. 7. In addition to the three literacy and math benchmark assessments, the district expects teachers to administer four interim assessment block (IAB) assessments throughout the year. 8. There is minimal evidence that the wide variety of data generated from the required common assessments is systematically used for assessing program effectiveness and guiding curricular decision-making at the district, site, or classroom levels. The CCEE quarterly review process addresses the strengths and weaknesses of the district’s continuous improvement actions but does not provide detail about the curricular program based on student assessment data. Pupil Achievement 149 Recommendations for Recovery 1. The district should fully implement the goals and action steps included in the Instructional Plan, Strategic Plan and LCAP related to common assessments, with a focus on appropriate use of the data generated by those assessments, to strengthen the district curricular and instructional programs. 2. The district should fully implement a continuous improvement cycle to assess strengths and weaknesses of the instructional program by: • Implementing and maintaining common assessments. • Participating in regularly scheduled CoI analysis at the cabinet and Educational Services levels. • Holding CoIs at every principals’ meeting. • Collaboratively establishing measurable goals and action steps to address identified curricular and instructional needs at the site level. • Monitoring progress toward those goals and adjusting actions as necessary. • Developing, implementing, and monitoring site and classroom evidence- based, measurable goals and action steps to address the identified weaknesses of the standards-based curricular and instructional program. 3. The district should continue to refine/expand data analysis displays to include student group data whenever available, particularly for ELLs, African Americans and SWDs. In addition, include the number of students represented by reported percentages to minimize the potential misinterpretation of assessment results due to the variation in the numbers of students completing assessments within and between years. 4. The district should consider how to support full implementation of the full range of tools and resources provided with each of the district-required assessments (e.g., analysis tools, item-level data, DOK information, hand scoring guides and protocols, grouping tools, CAASPP Tools for Teachers). 5. The Educational Services staff should continue to prompt, monitor and review completion rates to achieve the 95% completion rate goal. 150 Pupil Achievement Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 151 2.5 Curriculum Professional Standard The LEA has adopted a plan for integrating technology into curriculum and instruction at all grade levels to help students meet or exceed state standards and local goals. Findings 1. The district has a draft Technology Plan 2020-24 and a technology focus group that meets at least monthly. The district reported that IT staff turnover continues to be an issue and that IT maintenance and staff support has been difficult. The district reported several vacant positions related to IT. 2. The draft Technology Plan provided to FCMAT stated: “By June 2022, 50% of students will demonstrate grade-level aligned information literacy skills in support of demonstrating mastery of embedded technology,” and “100% of students will create projects using technology resources. These projects will evidence students’ proficiency in ELA, Mathematics, and Science and EL growth targets.” Although the effective integration of technology with instruction was a component of some of the classroom walk-throughs conducted by FCMAT, there was inconsistent evidence that students use technology for collaboration, research or other instructional purposes besides accessing instruction, taking assessments and word processing. 3. The integration of technology was more evident and used in all schools and grade spans compared to previous review periods. Recommendations for Recovery 1. The district should continue to review options for providing a continuum of professional learning to teachers on the use of technology and information literacy for students with the expectation that teachers would implement those new strategies into their daily instruction. Once professional development has been provided, monitor implementation using district walk-throughs. 2. The district should continue to address the internal capacity to fully implement the Technology Plan. This assessment should include an analysis of its structure and adequate staffing to provide technology professional learning, coaching and user support. 3. For technology, the district follows the substitution, augmentation, modification and redefinition (SAMR) model. The district should move from substitution and augmentation levels to modification and redefinition levels. 4. The district should continue to strive to fully staff and retain all IT positions. 152 Pupil Achievement Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 153 3.1 Instructional Strategies Legal Standard The LEA provides equal access to educational opportunities to all students regardless of race, gender, socioeconomic standing, and other factors. The LEA’s policies, practices, and staff demon- strate a commitment to equally serving the needs and interests of all students, parents, and family members. (EC 51007) Findings 1. A review of district policy, professional learning opportunities, and interviews with district staff continue to indicate that most students are provided with equal access to educational opportunities regardless of race, gender, socioeconomic standing, and other factors. The district provided race and equity training for all employees throughout the year. 2. Board policies continue to demonstrate a commitment to equally serving the needs and interests of all students, parents, and family members. 3. School sites report that they continue to strive to consistently demonstrate the commitment to equally serving the needs and interests of all students, parents, and family members. 4. All school sites received a full-time parent liaison to ensure that initiatives are in place to include parents and all those affected in the decision-making process, as well as include parents and those affected in the life of the school. 5. Some schools have intentional systems for identifying and remediating instruction for students with identified instructional needs, but the variation among sites continues to result in inequitable access for all students. Although the district has a process and plan for MTSS, implementation varies among school sites. 6. The district has a detailed plan for the delivery of daily, designated ELD targeted to students’ language proficiency levels. 7. Although there was evidence of thoughtful planning and lesson design for the delivery of instruction for ELLs, this varied among school sites and classrooms in each school site. 8. A specific set of district deliverables is in place using digiCOACH to monitor practices during both designated and integrated ELD. This is to ensure that students are learning about the language and using it for meaningful purposes to support both language acquisition and content learning. 9. The district has focused on delivering designated ELD instruction. The implementation of integrated ELD as a single, cohesive system of support for ELLs varied greatly from site to site as evidenced through classroom observations. 154 Pupil Achievement 10. In the recently released state list of schools identified for support under the Every Student Succeeds Act (ESSA), the district’s African American student group was newly identified as in need of targeted assistance. Recommendations for Recovery 1. District personnel and site leadership should consistently use the district’s specific set of deliverables to monitor the emerging practices of designated ELD at each school site. Special attention should be paid to providing students with language development that allows for full participation and access to the core curriculum. 2. The district should place additional focus on training all instructional staff on integrated ELD strategies to ensure quality core instruction for all students. 3. The district should continue to use data collected during ELD program monitoring and observations to inform professional learning and direct support to classroom instruction to provide for continuous improvement. 4. The district should continue to monitor and provide direct support to school sites to ensure consistent districtwide MTSS, thus ensuring equitable access to instructional programs and support for all students, particularly those identified for targeted assistance. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 155 3.6 Instructional Strategies Legal Standard The LEA provides students with the necessary courses to meet the high school graduation re- quirements. (EC 51225.3) The LEA provides access and support for all students to complete UC and CSU required courses (A-G requirement). Findings 1. The district continues to provide the courses, access, and support needed to meet the high school graduation requirements and for students to complete the courses required by the University of California (UC) and California State University (CSU). The Educational Services Department continues to evaluate master schedules each spring to ensure availability of courses and make certain they contain the rigorous courses required to prepare students for higher education. The district continues to make a concerted effort to ensure that all core classes and electives meet A-G requirements. The district continues to focus its efforts on course offerings for ELLs to ensure that they are enrolled in both an English class, as well as ELD so that they can meet A-G requirements. Counselors continue to be the main communicators of A-G requirements for students. 2. All students continue to have access to core subjects via the Apex online courses (UC approved), and teacher facilitators are available to assist with credit recovery or grade improvement. 3. According to Ed-Data, the district experienced a significant increase in the cohort graduation rate from 86.2% in 2020-21 to 91.1% in 2021-22, up from 87.2% in 2019-20 and 88.5% in 2018-19. The district’s graduation rates are disproportionate by race/ ethnicity and gender, and certain other groups have a lower graduation rate, including SWDs and ELLs who had an 87.6% and 85.7% graduation rate, respectively, in 2021-22. 4. According to Ed-Data, the percentage of cohort graduates meeting UC/CSU course requirements increased from 52.4% in 2019-20 to 62.2% in 2020-21 and dropped to 46.8% in 2021-22. Similarly to graduation rates, disproportionality exists in the district’s percentage of cohort graduates meeting UC/CSU course requirements by race/ethnicity and gender, and certain groups are less likely to meet UC/CSU course requirements. This includes SWDs and ELLs, with 25% and 34.1% of students in those categories meeting UC/CSU course requirements, respectively, in 2021-22. 5. The college and career readiness performance indicator, as reported on the California School Dashboard (Dashboard), measures how well a district or school is preparing students for success after high school. In 2018-19, the last year college and career readiness was reported on the Dashboard, the district was given an overall yellow performance status of 18.9% of students being prepared. That same data shows a large discrepancy between school-level rates. The individual sites ranged from a high of 46.5% to a low of 9.5%. College and Career data was not reported on the Dashboard for 2021-22. 156 Pupil Achievement 6. In 2020-21, the advanced placement (AP) data reported by the College Board indicates that 241 students took the AP exam, a decline of 3.2% of the overall number of students taking exams, and 24 students received a score of 3 or higher, a significant decrease from 68 the prior year. 7. Classroom observations continue to show a significant difference in and between the various high schools in effectiveness of instruction and student engagement level. 8. Although the continuation high school effectively addresses the needs of students who qualify for alternative education, there continues to be few formalized opportunities for students to receive early intervention and academic support at the two comprehensive high schools. Most interventions are offered through the Apex program or by individual teachers who identify struggling students. A new contract for tutoring to support students began in the winter of 2023. 9. The district continues to offer independent study options and summer school for core courses. Recommendations for Recovery 1. The district should continue to ensure that every comprehensive high school offers classes on campus that will fulfill the A-G requirements qualifying students for admission to a UC or CSU. 2. The district office and principals of secondary schools should continue efforts to upgrade the rigor and instruction in UC- and CSU-required courses (A-G requirement) to adequately prepare students for higher education. 3. The district should analyze data to address disproportionality by race/ethnicity and gender and for certain student groups, such as ELLs and SWDs, in the district’s graduation rate and in the percentage of students meeting UC and CSU course requirements. A plan should be developed to address the root causes. 4. The district should continue to use counselors to message A-G requirements to students. 5. The district should assess current AP exam data and determine why fewer students took AP exams than the prior review period. Support strategies for students in Advanced Placement classes should be provided to ensure successful completion. 6. The comprehensive high schools should develop systems for early identification and formalized support of struggling students who do not meet the required academic measures. Pupil Achievement 157 Standard Fully Implemented July 2013 Rating: 5 July 2014 Rating: 7 July 2015 Rating: 9 July 2016 Rating: 9 July 2017 Rating: 10 July 2018 Rating: 10 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 158 Pupil Achievement 3.7 Instructional Strategies Legal Standard The LEA provides an alternative means for students to complete the prescribed course of study required for high school graduation. (EC 51225.3) Findings 1. Alternative education at the continuation high school continues to remain stable and provide practical options for students and families who struggle to succeed in the comprehensive high schools. 2. Staff continues to report a priority of effective communication between the continuation high school and the other high schools when a student transfers between schools, allowing for a smoother transition. 3. Although seniors receive priority, the district’s continuation high school continues to serve students from other grades. 4. There is a strong demand for coursework at the continuation high school program, requiring cycling of students back and forth to the traditional high schools each quarter. 5. Students continue to be able to recover credits or improve D grades by completing the UC -approved coursework through the Apex online program. The district continues to provide an alternative means for students to complete the prescribed course of study required for high school graduation at each of its high schools, which includes the following: • Referral to Inglewood Continuation High School (ICHS) for inclusion in the general educational development high school diploma program. • An outreach independent study program through the district’s continuation high school. • Participation in the Southern California Regional Occupational Center (SCROC). • Participation in the El Camino College concurrent enrollment program. • Participation in summer school to obtain necessary credits. 6. The district began Saturday school sessions in winter 2023 to provide opportunities for high school students to make up missed time/attendance. Recommendations for Recovery 1. The continuation program at ICHS should continue to be made available to students who struggle at other high schools. Pupil Achievement 159 2. The district should continue to use counselors and prioritize communication between the continuation program and other high schools when students transfer between programs. 3. The district should consider options for students to stay at the continuation high school for longer than a quarter when a student is making good progress and would benefit from an enrollment period longer than one quarter, thus providing individualized support in a safe and supportive academic environment. 4. The district should continue to encourage students to participate in SCROC, summer school, the independent study program, the Apex online program and the El Camino College concurrent enrollment program, if eligible. 5. The district should continue to offer Saturday school sessions for high school students to make up missed time/attendance. Standard Fully Implemented July 2013 Rating: 5 July 2014 Rating: 7 July 2015 Rating: 8 July 2016 Rating: 9 July 2017 Rating: 10 July 2018 Rating: 10 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 160 Pupil Achievement 3.10 Instructional Strategies Legal Standard The LEA has adopted systematic procedures for identification, screening, referral, assessment, planning, implementation, review, and triennial assessment of students with special needs. (EC 56301) Findings 1. The district CAO directly oversees special education. In fall 2020, the district hired a new executive director of special education who has remained in that position. The executive director oversees the administrator of compliance who began in September 2018 and is responsible for returning SWDs in nonpublic schools to the district. Starting in the 2021-22 school year, the program specialist job description was rewritten to extend that position’s day to create more time to work on individualized education program (IEP) compliance. The program specialist positions were also reorganized to focus support by program as opposed to by school. Additionally, the district developed a job description and hired a special education administrator of instruction in 2021-22. This position is focused on supporting SWDs in their least restrictive environment (LRE), returning certain SWDs in nonpublic schools to the district, MTSS, principal and teacher accountability, and student achievement. 2. The Special Education Department leveraged the banked time/early student release to provide targeted professional learning to special day class teachers, psychologists, program specialists and resource specialists on topics such as the use of the Unique curriculum, IEP basics, use of data, Rethink Ed, and the Policy and Procedures Manual (PPM). The administrator of instruction leads many of these professional developments. 3. Compliance has been a continued focus for the special education leadership team. The district reported using an IEP checklist to internally monitor IEPs to ensure compliance. The district explained that program specialists are responsible for identifying IEP checklist trends, and presenting and discussing those with special education teachers and related service providers. Program specialist meeting agendas provided to FCMAT included a discussion on IEP compliance and a list of the number of overdue, unsigned and unaffirmed IEPs. Special Education Department evidence provided to FCMAT demonstrated the department collaborates with sites on IEP calendars to ensure IEPs are scheduled prior to due dates. In addition, special education staff continue to use the various resources introduced during the last review period (i.e., IEP Compliance Checklist, English Learner Checklist, Transition Checklist). Pupil Achievement 161 4. The district has created and regularly uses an Audit Tool to randomly select IEPs to: • Monitor the compliance of assessments, IEPs and transition plans. • Analyze the results to identify root causes leading to noncompliance. • Guide differentiated professional development for school leaders and school sites. 5. In 2021-22, the district’s Special Education Information System (SEIS) operator’s position was redesignated as a certificated position. This position is responsible for supporting IEP compliance, and an initial project for this position was to reconcile SEIS and Aeries to ensure that all SWDs were appropriately identified and coded. The district continues to struggle with this reconciliation. 6. While the district has provided each school with the Beyond SST platform, it is not frequently used to support the student study team (SST) process. Each school site is required to use the online SST system, Beyond SST, for managing referrals and progress of struggling students. The online SST system requires recording of the interventions used with a student, but because of inconsistencies in the type of interventions offered at various school sites, significant numbers of underachieving students are still referred to special education with little to no documented interventions. A special education referral tracking form was developed and is used to track the students who are in the SST process prior to referral for a special education assessment. 7. School psychologists meet weekly during banked time/early student release, and meeting agendas indicate initial and triennial assessment request data is analyzed at those meetings. Additionally, beginning in November 2021, the Special Education Department began maintaining a spreadsheet populated monthly by the school psychologists, which is used to facilitate a conversation addressing patterns in referrals for assessment, requests by school site, SST/MTSS data, indicators of possible overidentification, etc. The team then determines if targeted support is needed for a staff member, site, group of sites, etc. 8. The Special Education Department is tracking and has reviewed initial assessment data by site. A comparison report, listing initial assessments conducted between August and January, showed the district conducted 38 initial assessments in 2020-21, 82 in 2021-22, and 48 in 2022-23. 9. The Special Education Department continues to meet with the CAO and CCEE to monitor the completion and quality of initial, annual, and triennial IEPs. Recommendations for Recovery 1. The district should continue to focus on complying with IEP timelines through IEP progress reports to: • Monitor upcoming annual IEPs by month. 162 Pupil Achievement • Communicate and provide data reports indicating IEP completion status to site administrators and executive directors. • Hold personnel accountable by requiring and monitoring IEP schedule calendars and reflecting IEP completion in evaluations. • Hold site leaders responsible for facilitating the IEP process and timelines. • Continue to track referrals monthly and compare them to students who qualified as eligible for special education to determine if the referrals are valid. Look for trends in students who qualify as well as sites that may overrefer students for special education instead of offering appropriate interventions. 2. The district should continue to build the capacity of all staff to support all students by: • Providing ongoing and systemic annual training for all site administration and special education staff to implement the content of the updated special education procedural manual. • Providing differentiated professional learning based on data and school requests. • Providing training on the SST purpose and process and the use of the Beyond SST system to document and monitor student progress. • Holding schools accountable for using the Beyond SST platform and the use of current data to inform students’ response to interventions. • Providing training/professional learning to all teachers, focusing on strategies to support struggling students and the interventions that should be offered in the general education classroom prior to any referral for an SST that could lead to possible special education placement. 3. The district should continue to use the Audit Tool to collect data to be used for decisions related to special education. 4. The district should use program specialists to provide differentiated support and training based on site data. 5. The district should ensure that the data reconciles between SEIS and Aeries for SWDs. 6. The district should continue having the executive director of special education attend principals’ meetings to increase the level of communication between school sites and special education leadership. This will continue to help district administration to identify areas of concern and allow them to facilitate resolution when needed. Pupil Achievement 163 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 164 Pupil Achievement 3.12 Instructional Strategies Legal Standard Programs for special education students meet the least restrictive environment provision of the law and the quality criteria and goals set forth by the California Department of Education and the Individuals with Disabilities Education Act. (EC 56000, EC 56040.1, 20 USC Sec. 1400 et. seq.) Findings 1. Interviews indicate that LRE continues to be a focus for the district, which requires that programs for students with disabilities meet the LRE provision of the law and the quality criteria and goals established by the CDE and the Individuals with Disabilities Education Act (IDEA). In its most recent data released, the CDE’s 2020-21 Special Education Annual Performance Report Measures shows that the district does not meet all three targets of LRE measures for students ages six to 22. 2. The district established a priority to increase the percentage of SWDs served in the LRE in the Instructional Plan. • The CDE’s 2020-21 data for Element 5a indicates that 42.26% of students are in the general education class for instruction for 80% or more of the day, which is less than the statewide target of more than 58% of students. • The data for Element 5b indicates that 41.23% of students are in the general education class for instruction for less than 40% of the day, which is more than the statewide target of less than 19.5% of students. • The data for Element 5c indicates that 6.76% of students are placed in a separate school, which is more than the statewide target of less than 2.9%. 3. To work toward reducing the number of SWDs in separate schools, the Special Education Department assigned one program specialist to nonpublic schools in 2021-22 to facilitate consistent communication and practices with the nonpublic school partners. Additionally, the district opened a new classroom focused on therapeutic behavior support for SWDs at Morningside High in January 2022. The intent is to use this placement option to keep SWDs in a program on a comprehensive district campus instead of a separate school setting. 4. District leadership continues to identify LRE as an area needing constant communication of expectations and building capacity of site leadership and instructional staff to make appropriate placement decisions during IEP meetings. The district has included an LRE goal in the Instructional Plan to support a focus on instruction for students with disabilities. 5. The district is developing two schools identified as inclusion sites. LACOE has provided technical support and professional learning for these schools. Pupil Achievement 165 Recommendations for Recovery 1. The district should provide professional learning to: • Education specialists and related service providers on how to properly add IEP services and document percentage of time out of the classroom. • All staff serving as administrative designee at IEP meetings on verification of the percentage of time out of general education. • All instructional staff, related services providers and administrative designees specific to understanding the continuum of services and policies and procedures related to placement of students in the LRE. • All teachers, special education paraprofessionals and administrators in effective teaching strategies and inclusive practices. • Support service providers with specialized 1-on-1 training and monitoring as needed. 2. The district should continue to monitor progress toward LRE by: • Auditing a sample of IEPs regularly to ensure the percentage of time out of the general education setting is reported accurately. • Analyzing data to examine placement options and the potential harmful effects of placement for each disability by site, group, and grade level. • Monitoring the level of support special education teachers provide to general education teachers when students are mainstreamed and facilitate designated meetings between these teachers to regularly discuss strategies to help students be successful in the mainstream environment. • Holding site administrators and staff accountable for following all policies and procedures, and any noncompliance should be reflected in evaluations. 3. The district’s special education leadership should continue to be aggressive in its efforts to ensure all schools and programs for special education students meet the LRE provision of the law and the quality criteria and goals established by the CDE and the IDEA. 166 Pupil Achievement Standard Partially Implemented July 2013 Rating: 6 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 167 3.13 Instructional Strategies Professional Standard Students are engaged in learning, and they are able to demonstrate and apply their knowledge and skills. Findings 1. The district’s LCAP, Strategic Plan, as well as the schools’ SPSAs, delineate the issue of low student achievement throughout the district. Specifically, the district has high percentages of students not meeting grade-level standards and high school students failing one or more classes. The district has also noted that higher percentages of ELLs and SWDs are in these categories than are other student groups. The district’s leadership has identified, and FCMAT agrees that there are several contributing factors, but the main one is the lack of consistent, effective first instruction with rigor being the greatest barrier to student success. The district developed coherent, systematic plans, such as the MTSS Plan 2021-24 and the Instructional Priorities Plan 2021-23, to ensure the accountability of the 10/10/95 goal. The 10/10/95 goal is to have 10% of students making growth on literacy benchmark assessments, a 10% decrease of students who fall in the “far below” category of achievement, and a 95% completion rate on required assessments. The district’s focus is beginning to translate into improved student achievement, as documented by the district’s formative assessment results. The district used the digiCOACH classroom walk- through as the tool for principals to use to monitor instruction. The components of the Instructional Priorities Plan 2021-23 are included in that program. 2. During classroom observations, most teachers delivered instruction to students during designated time slots that matched the posted instructional schedule. Some teachers were observed using graphic organizers, conducting close reading activities, checking for understanding and facilitating small-group discussion/group work. However, students were also observed being compliantly engaged in the instructional process for most classrooms visited. Additionally, differentiation of instruction or response to intervention (RtI) was minimally observed. Instructional practices were observed to vary widely throughout the district. 3. The district has developed a draft memo regarding lesson plan expectations, pending negotiations. Inconsistency regarding how principals reviewed and monitored teacher lesson plans was noted by FCMAT. 4. The Theory of Action Plan and the SIR progress monitoring tool developed in collaboration with LACOE and CCEE are used to guide instructional improvement. 168 Pupil Achievement Recommendations for Recovery 1. The district should continue to focus on student achievement by: • Communicating a committed effort on the implementation of the MTSS process and the Instructional Plan. • Implementing rigorous goals and targets for student achievement. • Using the continuous improvement models, CoI, systemically to monitor and identify course corrections needed to increase student outcomes. 2. The district should continue to systematically and incrementally implement the components of effective first instruction, (currently focus, engagement and differentiation) identified in the Instructional Plan as follows: • Clearly define and outline the high impact instructional strategies expected to be used systemwide. • Articulate and monitor the expectations for principal walk-throughs including the provision of effective feedback and conferencing using the district’s observation platform (digiCOACH). • Continue to conduct CoI activities with principals using quantitative and qualitative data after walk-through data has been collected, and continue to calibrate implementation ratings to ensure practices and expectations are consistent districtwide. • Provide a differentiated continuum of support to principals and teachers as indicated by the digiCOACH data and school/classroom observations. 3. The district should develop and communicate the expectations for lesson planning that is intentionally designed according to the district’s Instructional Priorities, and ensure the lesson plans include the district’s identified strategies for effective first instruction, and they reflect the rigor of the standards taught that week. Lesson plans should reflect strategies to support various student populations. 4. The district should clearly articulate the use of supplemental materials for Tier 1 and Tier 2 instruction including those already in place such as i-Ready and Achieve 3000. 5. Schools should use the CoI process in a continuous improvement cycle to monitor effectiveness of current practice, adjust instructional strategies and identify and provide student support based on the data and student work. 6. The district should continue to provide teachers with a continuum of ongoing professional learning opportunities that are aligned with the district’s instructional expectations and the CCSS. Working with the instructional leadership team at the school level, each grade or department should identify and set achievement targets for all teachers. 7. The district should continue to effectively use its instructional coaches to support teachers and principals. Consider expansion of the coaching process to effectively support schools. Pupil Achievement 169 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 170 Pupil Achievement 3.15 Instructional Strategies Professional Standard The LEA optimizes opportunities for all students, including underperforming students, students with disabilities, and English language learners, to access appropriate instruction and standards- based curriculum. (DAIT). Findings 1. Curriculum design and implementation of designated ELD instruction for ELLs were reportedly used, including use of approved curriculum for designated ELD. The quality of the delivered instruction continues to vary across the district and in some school sites. 2. Information is readily available to teachers on the students in their classrooms who are identified as having learning disabilities or who are ELLs; however, instructional strategies for these students have varying implementation. 3. The district is implementing a MTSS system, and needs to fully develop each tier of the process to meet the needs of struggling students. Support for struggling students continues to vary by school site. 4. To support positive school climate and student behaviors, schools have implemented PBIS programs, following the district plan. Structures for delivery and professional learning in this area continue throughout the district although implementation of this process is varied across the district. 5. High schools offer ELD in a two-block format, allowing ELLs to receive both designated ELD, as well as grade-level content in English. Recommendations for Recovery 1. District administrators and site principals should continue to work collaboratively to refine processes and consistently implement MTSS. The district should provide additional support for the sites that are not fully implementing the process. 2. The district should continue to review and reinforce core strategies for integrated ELD support in the core classrooms for principals and teachers. Principals should continue to observe classrooms to ensure that sound instructional strategies are used to provide ELLs access to the core curriculum, including continuing the practice of daily designated ELD. Special attention should be paid to increasing rigor as ELLs move through grade levels. 3. The district should continue to explore programs for board approval for designated ELD instruction at the elementary level. Pupil Achievement 171 4. Principals’ classroom observations should continue to focus on collecting data on district- established expectations to ensure appropriate targeting of professional learning planning to support instruction, including instruction for SWDs and ELLs. 5. The district should continue to examine and refine PBIS programs at each school site, providing additional support for the sites that are not fully implementing the process. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 172 Pupil Achievement 3.16 Instructional Strategies Professional Standard The LEA makes ongoing use of a variety of assessment systems to appropriately place students at grade level, and in intervention and other special support programs. (DAIT) Findings 1. The district Instructional Plan, Strategic Plan and LCAP continue to include goals and action steps related to the use of assessments to appropriately place students at grade level, and in intervention and other special support programs. 2. Assessment platforms have been identified in ELA and mathematics for grades K-8. Staff reported that two platforms, DIBELS and Achieve 3000, are not user friendly and do not allow teachers to disaggregate data at a deeper level. 3. The district continues to have a goal that all sites will test 95% of their students using the required assessments to have reliable data to support the CoI process. Almost all sites meet or exceed this goal, and the others are very close. 4. In addition to the district-required i-Ready, DIBELS and Achieve 3000 assessments, teachers at all grade levels are expected to use site/grade level selected formative assessments for both ELA and mathematics three times a year. Grade levels may select from the assessments provided by the core instructional materials programs or from the Smarter Balanced interim assessments to meet this requirement. 5. Individual teachers are expected to use results from the i-Ready, DIBELS and Achieve 3000 assessments to identify students for in-class Tier 1 and Tier 2 support, tutoring support through the Hey Tutor program and after-school teacher tutoring. Progress monitoring of student performance is also based primarily on i-Ready, DIBELS and Achieve 3000 results. 6. The process for effective, evidence-based use of assessment information to make decisions on student placement varies between school sites. 7. The district is implementing a comprehensive MTSS that includes systematic tiered intervention and other special support programs to meet student needs. The addition of the ALTs at the elementary sites has allowed those sites to target students needing Tier 2 interventions. 8. There is no districtwide Tier 3 intensive intervention system/program to meet the needs of students who are performing significantly below grade-level expectations in ELA or mathematics, although some individual sites have been able to provide Tier 3 interventions. Pupil Achievement 173 Recommendations for Recovery 1. The district should develop and monitor measurable action steps that show students are receiving effective first instruction and based on data are provided interventions with specific support programs, as needed. 2. The district should provide ongoing professional learning, including guided practice activities, to administrative and instructional staff on the use of assessment results as a data point for instructional grouping, targeted reteaching, and classroom intervention or acceleration programs. Include content in the professional learning experiences that is designed to deepen teacher awareness and their use of the variety of resources available in the curricular programs and required assessments. 3. The district should select and fully implement diagnostic and progress monitoring assessments designed to provide detailed information on student learning strengths and needs for use with students (Tier 1, Tier 2, Tier 3) that do not demonstrate progress with classroom level and/or after-school interventions. 4. The district should assess students using a variety of assessment tools to ensure they are placed in appropriate academic and/or behavioral support programs based on diagnostic evidence. 5. The district should develop and provide a clear model, including resources and training, to ensure effective first instruction in all classrooms. Refine and expand Tier 2 supports and develop a districtwide Tier 3 intensive intervention system for ELA and mathematics for students performing significantly below grade-level standards. 6. The district should continue to partner with the CCEE and LACOE (e.g., support services, assessment network, and other relevant county office staff) to strengthen and deepen implementation of a comprehensive districtwide MTSS system, including the use of a variety of assessments to identify student needs, determine placement in support programs, and to monitor learning progress over time. 174 Pupil Achievement Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 175 3.17 Instructional Strategies Professional Standard Programs for English language learners comply with state and federal regulations and meet the quality criteria set forth by the California Department of Education. Findings 1. The district has developed a clear plan for ELLs, which explains how programs for ELLs comply with state and federal regulations and meet the quality criteria established by the CDE. 2. Designated ELD instruction was observed in classrooms throughout the district in accordance with the district English Learner Plan. Limited integrated ELD instruction was observed. 3. The district continues to use a reclassified student monitoring record to provide for review and monitoring of individual student’s needs after they have exited the ELL program. 4. Data regarding ELD instruction is available using a classroom instruction observation tool (digiCOACH). 5. In some classrooms and at some school sites, data is systematically and consistently analyzed to focus on the progress of ELLs, allowing teachers to adjust instructional strategies. 6. The high school level has a consistent time block and plan for the delivery of daily designated ELD, as well as a second block of English as a subject area. Recommendations for Recovery 1. The district should continue to use the available classroom instruction observation tool to provide data for site principals and classroom teachers to adjust instructional strategies. 2. The district should continue implementing its system for monitoring ELLs and reclassified students to ensure they continue to make academic progress. 3. The district should ensure that district and site-level data is consistently reported and analyzed to measure the effectiveness of instruction for ELLs and student progress. 4. District office personnel should continue implementing a systematic approach to helping site principals and teachers in serving ELLs and holding them accountable for complying with state and federal regulations on instructional support for ELLs. 176 Pupil Achievement Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 3 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 177 3.18 Instructional Strategies Professional Standard The LEA employs specialists for improving student learning, including content experts and spe- cialists with skills to assist students with specific instructional needs. Findings 1. The district employs some instructional coaches that have both elementary and secondary levels of experience. Due to the limited number of district instructional coaches, each serving multiple sites, they focused their initial support on new teachers and expanded to offer support to other teachers when availability allowed. 2. In FCMAT’s interviews with teachers and school site leadership, district instructional coaches are viewed as a valuable aspect of the school site instructional team. 3. Although the district only has four instructional coaches, they worked effectively with classroom teachers, site administrators, and district personnel to provide both the professional learning and immediate support necessary for quality service and instruction. 4. The district implemented the ALT positions at each elementary site to provide targeted support for struggling students in a small group, pull-out instruction and some push-in support in classrooms. In addition, they provided support in the CoI process. Recommendations for Recovery 1. Given the district’s high number of ELLs and the emphasis on providing instruction using the California ELD standards, the district should continue to provide professional learning for the instructional coaches addressing ELD and delivery of services to ELLs districtwide. 2. The district should consider expanding instructional coaching support and providing ALT services at all sites within the district based on available financial resources. 178 Pupil Achievement Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 179 3.22 Instructional Strategies Professional Standard The LEA offers a multiyear, comprehensive high school program of integrated academic and tech- nical study that is organized around a broad theme, interest area, or industry sector. (EC 52372.5, EC 51226) Findings 1. Both comprehensive high schools offer dual enrollment opportunities for students through El Camino College. 2. The district has increased the number of dual enrollment opportunities and increased the articulation between the district and El Camino Community College ensuring programs are more aligned with workforce development and A-G requirements. 3. The district has a clear understanding of A-G requirements. 4. The district has a clear process for supporting students and parents in their understanding of the necessity of meeting A-G requirements. 5. The district has a clear process for ensuring that data for A-G requirements is clear and accurate. 6. The district has committed the necessary resources to ensure that all students can meet A-G requirements. 7. The district has five CTE pathways that include: Health, Science and Medical Technology; Engineering and Architecture; Arts, Media and Entertainment; Information and Communication Technologies; and, Hospitality, Tourism, and Recreation. There are various CTE options offered for students across all high school sites. Recommendations for Recovery 1. The district should continue communication and partnership with El Camino College to continue dual enrollment opportunities and innovative practices in providing coursework to students. 2. The district should continue to offer programs and pathways based on community- identified interests and needs. 3. The district should continue to implement a system of support to ensure that the degree of execution and delivery of programs and courses is consistent from school to school. 180 Pupil Achievement 4. The district should determine implementation progress of the proposed strategies to increase A-G completion rates. Continued focus to counsel students to ensure more successful completion of A-G requirements should include more frequent meetings between counselors and students, more than once or twice per school year. See Standard 3.6 for more information. Standard Fully Implemented July 2013 Rating: 5 July 2014 Rating: 5 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 7 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 181 4.3 Assessment and Accountability Professional Standard The LEA has developed summative and frequent common formative assessments that inform and direct instructional practices as part of an ongoing process of continuous improvement. Findings 1. The district Instructional Plan, Strategic Plan and LCAP include goals and action steps related to the implementation of an assessment system that provides district and classroom-level assessment data to measure student mastery of the content standards and inform decision-making at all levels of the district. 2. The district goal of a 95% completion rate for all required assessments has provided more reliable data to be used in the CoI and PLC process. District and site leaders expect this data will be used to inform instruction and better meet the needs of students. 3. Through the CoI and PLC processes, there is more evidence that data from the required assessments is beginning to be used systematically across the district to improve classroom instructional practices. 4. District ALTs have been trained in data review and interventions and can provide support to sites in the CoI and PLC processes. 5. District expectations for the use of a CoI to review and analyze data from district-required assessments have been articulated during training and in memos from the CAO. How this information is shared with teachers by site administrators varies across school sites. 6. The district continues to use a CoI process and data analysis template for all school sites. The template has a component for individual teacher reflection/analysis/planning and a component for grade-level/content area team reflection/analysis/planning. Professional learning on the CoI process continues to be provided to administrators and teachers. 7. During this review period, the district instituted banked time for teacher professional learning, providing 90 minutes weekly through early student release on Tuesday afternoons. The banked time/early student release schedule for professional learning is provided by the district and is reviewed regularly at principals’ meetings. Recommendations for Recovery 1. As addressed in the Instructional Plan, Strategic Plan and LCAP, the district should continue to focus on effective, continuous use of student performance data to guide instructional decisions at the district, site, and classroom levels as an urgent priority. Ensure that district Educational Services staff continue to model this process publicly and 182 Pupil Achievement explicitly in making evidence-based district-level instructional decisions. Continue to implement action steps to address identified district-level problems of practice. 2. The district should continue the expectation that sites will have at least 95% of students taking the district-required assessments to have reliable data to inform decisions. 3. The district should continue to frequently and explicitly discuss the purpose of required assessments and the role they play as a component of a coherent instructional system in Tiers 1, 2, and 3. Continue to communicate the connection of assessments/assessment data to the district identified Instructional Priorities, practices and relevant performance indicators. 4. The district should establish clear, explicit expectations for how district disseminated communication documents and videos are to be shared and discussed with teachers by site administrators. Continue to review site meeting agendas and sign-in sheets to ensure that all teachers receive and have an opportunity to discuss the content of the communications. 5. The district should continue to communicate the importance of the CoI process as a continuous improvement tool/strategy. Continue applying the steps of the process to selected data, formulate a measurable goal, implement action(s), progress monitor and evaluate the results of the actions during subsequent CoI sessions. 6. The district should increase the emphasis on frequent use of the full range of detailed data and resources/tools for informing and directing instruction that are available in the district -required assessments programs (e.g., standards data, student by student item- level analysis, depth of knowledge levels of items, planning templates, grouping strategies). 7. The district should continue to provide ALT support to teachers and site leaders in data review and interventions. 8. As guided and monitored by the CAO, the executive directors of elementary and secondary education should provide frequent differentiated on-site support to principals and monitor progress on the development of evidence-based, measurable goals and instructional action plans generated by grade-level/content area CoI teams. The executive directors should ensure that teacher teams and principals are accountable for implementation and progress monitoring of the action plans. Pupil Achievement 183 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 184 Pupil Achievement 4.4 Assessment and Accountability Professional Standard The LEA provides an accurate and timely school-level assessment and data system as needed by teachers and administrators for instructional decision-making and monitoring. Findings 1. The district Instructional Plan, Strategic Plan and LCAP include goals and action steps that require the use of data-driven instructional decision-making and monitoring. 2. The district system provides school and classroom-level assessment data to principals and teachers in a timely manner. A wide range of detailed information can be generated through the assessment reports available, including grade level, teacher, individual student, content standard, assessment target, item level, and depth of knowledge-level (DOK) results. The Aeries student information system provides additional student-level data. 3. There is evidence that the broad range of assessment data available in program reports is beginning to be analyzed and used to guide instructional decision-making at the site and classroom level. 4. The district has established expectations for the use of data for instructional decision- making and monitoring of student progress and has developed data analysis structures and procedures. 5. Most schools met a 95% completion rate target for the 2022-23 school year. A structure was put into place to support schools that did not meet the 95% completion rate for formative assessments. Recommendations for Recovery 1. The district should continue to communicate to all instructional staff the importance of timely completion of district-required assessments to provide data for instructional planning and monitoring. 2. The district should continue to monitor completion rates for required assessments at all grade levels and address noncompletion issues. Continue to hold principals and teachers accountable for completion of required assessments as calendared in the assessment schedule. 3. The district should continue to provide a continuum of professional learning opportunities to district and site administrators, instructional support providers and teachers to increase the capacity of all instructional staff to effectively analyze and apply data to district and site level instructional planning and to classroom instructional practices analysis. Pupil Achievement 185 4. The district should protect regularly allocated time during district and site staff meetings dedicated to understanding the full range and potential uses of the reports and tools/ resources available for the district-required assessments. These meetings should be part of a coherent, ongoing continuum of professional learning that focuses on the effective use of district-provided assessment data to accelerate student learning through improved classroom instruction. 5. The district should hold district and site administrators and teachers accountable for using the district, school and classroom level data provided by the district system to improve classroom instruction through targeted classroom observations, review of lesson plans, staff meeting and CoI meeting products (e.g., plans, schedules, lessons based on data analysis), and student work products. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 186 Pupil Achievement 4.5 Assessment and Accountability Professional Standard School staff assesses all students to determine students’ needs, and whether students require close monitoring, differentiated instruction, additional targeted assessment, specific research based intervention, or acceleration. Findings 1. The district Instructional Plan identifies key steps for implementation of an integrated MTSS framework to provide individual student support. 2. A districtwide MTSS as described in the California ELA/ELD Framework continues to be developed and implemented. Initial professional learning on the tiered MTSS system for academic and behavioral issues has been provided to administrators. Professional learning on the key elements of effective first instruction continues to be provided to staff. 3. The district requires completion of multiple academic assessments throughout the school year, as detailed in the district assessment schedule (see Standard 2.4). Some of these assessments are used as universal screening tools and yield data that can be used to help determine student needs for close monitoring, differentiated instruction, additional targeted assessment, intervention, or acceleration. Several required assessments, as well as the adopted instructional materials, have online tools and resources designed to support close monitoring, differentiated instruction, targeted assessment, and/or research-based intervention, or acceleration. 4. School staff use data from the district-required assessments inconsistently to identify student learning needs and determine whether students require close monitoring, differentiated instruction, additional targeted assessment, specific research-based intervention, or acceleration. Limited evidence was provided demonstrating regular teacher use of the tools and resources available through the assessments and adopted instructional materials to determine and address individual student learning needs. 5. In collaboration with ALTs, the district has identified diagnostic assessments, beyond the required district assessments, appropriate for use in determining the needs of Tier 2 students not responding to initial classroom intervention or for students identified at Tier 3 of the MTSS system (e.g., diagnostic reading inventory, diagnostic math assessment). The assessments are not used systemwide. 6. The MTSS Guide outlines the structure and components for a system with embedded intervention and enrichment. There is wide variation in how, when, at what level of intensity, by whom, and to whom academic intervention services are provided at individual schools during the regular school day. The Hey Tutor program is beginning to be implemented during the school day in the classroom setting, serving a limited number of students in need of intervention. Hey Tutor is also in place during after school hours. Pupil Achievement 187 Saturday school began midyear 2022-23 at the high school level to provide opportunities for students to make up absences and school work. 7. Support for students who are nonresponsive to Tier 1 instruction, such as small group and differentiation, were not evident systemwide. The district has expanded Tier 2 options with the addition of ALTs in the classroom, yet Tier 3 supports and programs are not in place. 8. The Educational Services Department has expanded district Gifted and Talented Education (GATE) identification and program offerings, such as extended day and a Saturday school program. 9. Implementation of differentiated instruction varied widely between school sites. 10. Principals conducting classroom observations have varying degrees of knowledge and skill regarding effective instructional and assessment practices. Some are not fully prepared to coach teachers to implement practices that would meet the diverse needs of students through differentiated instruction, close monitoring, additional targeted assessment, specific research-based intervention, or acceleration. Recommendations for Recovery 1. The district should continue to develop, support, and monitor the equitable, consistent, effective implementation of a comprehensive MTSS process at all sites by: • Using a variety of appropriate assessment tools to identify student needs and to determine which students require close monitoring, differentiated instruction, additional targeted assessment, specific research-based intervention, or acceleration. • Identifying progress monitoring procedures and tools to frequently assess student progress. • Ensuring that procedures and tools are identified for ongoing evaluation of program impact/effectiveness on instruction and student learning. • Continuing to provide after-school intervention as an additional opportunity to meet student learning needs. 2. The district should continue to provide a continuum of ongoing professional learning experiences to district and site administrators and teachers on the full, effective implementation of the MTSS model for student support, including: • High-functioning SSTs and CoIs. • In-depth, hands-on learning experiences on effective first instruction (e.g., lesson study, model lessons, in-class coaching). • Classroom-embedded professional learning experiences to the greatest extent possible. 188 Pupil Achievement • Appropriate Tier 1 strategies for differentiation and scaffolding for students in all classrooms. • Use of a variety of assessment tools with a focus on identifying those appropriate for Tier 2 and Tier 3 interventions to determine student needs for close monitoring, differentiated instruction, additional targeted assessment, specific research-based intervention, or acceleration. • Models for intensive intervention and acceleration service delivery during the regular instructional day. 3. At each instructional principals’ meeting, the district should provide site administrators with structured, guided practice applying specific techniques for supporting effective teacher use of assessment data to determine individual student needs for close monitoring, differentiated instruction, additional targeted assessment, specific research- based intervention, or acceleration. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Pupil Achievement 189 4.10 Assessment and Accountability Professional Standard The LEA and school site administration monitor fidelity of program implementation in the deliv- ery of content and instructional strategies. Findings 1. District expectations for the use of adopted core instructional materials have been established in the Instructional Plan, Strategic Plan and the LCAP and have been communicated verbally and in written form to principals and teachers. 2. Instructional Priorities have been identified and communicated to all staff through professional learning sessions on the Instructional Plan. 3. Effective first instruction has been identified as a part of the MTSS system. 4. The use of supplemental materials was observed in some classrooms at multiple school sites. District staff stated that a formal procedure for use of supplemental materials is being developed. 5. The district expects site principals to collect and review teacher lesson plans as one way to monitor fidelity to the articulated instructional program content and instructional strategies. 6. The district expectation is that principals will observe classroom instruction regularly. These observations provide another opportunity for principals to monitor program implementation. Principals are expected to identify teachers in need of targeted support and professional learning in the delivery of content and the use of prioritized instructional practices and to provide appropriate support to those teachers to increase their instructional effectiveness. 7. The district utilizes the digiCOACH tool for observing classroom instruction and gathering data on implementation of specific components of classroom instruction. District office and site staff are in the beginning implementation stage for this monitoring strategy. 8. There is considerable variance between school sites in the use of the digiCOACH tool for classroom observations. 9. The district executive directors of elementary and secondary education meet with each of their assigned principals a minimum of once per month. There is evidence of beginning implementation of a system for the executive directors to monitor/observe classroom instruction with the principals and to review results of principals’ classroom monitoring observation activities. 190 Pupil Achievement 10. Documentation of principal classroom observation/monitoring activities is available through the digiCOACH platform. The platform also allows users to see feedback provided to teachers. 11. Structures and clear procedures to ensure principal accountability for quantity and quality of classroom monitoring are not systematized and differentiated. Recommendations for Recovery 1. The district should continue to provide clear verbal and written expectations/guidelines for how and when principals share district level communications with site instructional staff. 2. The district should finalize and disseminate the procedure for obtaining approval for classroom use of supplemental instructional materials. Ensure that all Educational Services staff, principals, and teachers know the purpose of and the steps in the procedure. 3. The district should prioritize effective first instructional strategies as a focus for teachers, support staff, and leaders responsible for instructional supervision. 4. The district should differentiate the type of assistance and increase the frequency of site visits by the executive directors of elementary and secondary education for principals needing additional support. Ensure that time is spent during each visit conducting classroom observations with site principals and providing coaching, follow up, and monitoring of digiCOACH data to improve classroom instructional practices. 5. The district’s ongoing professional learning should include additional hands-on learning experiences for norming/calibrating the use of the classroom observation tool. 6. The district should collect site classroom observation data from principals at least monthly. Develop a system for that quantitative and qualitative data to be reviewed with each individual principal and his or her executive director of education. The executive directors of elementary and secondary education should submit summary data from their site observations (conducted with the principal) and those of each principal monthly to the CAO. Review the progress monitoring data during Educational Services meetings, principals’ meetings, meetings between individual site principals and their executive directors of education, and at individual school site staff meetings with teaching staff. 7. The district should continue to provide professional learning to all teachers on the observable, measurable components of the digiCOACH classroom monitoring/ observation tool. Ensure that teachers clearly understand the rationale for the chosen components and what evidence demonstrates effective, high-quality classroom implementation of each of those components. Pupil Achievement 191 8. The district should ensure that all classroom observations result in specific feedback provided to individual teachers focused on the continuous improvement in the delivery of effective first instruction, use of district-adopted instructional materials, and the use of the district core instructional practices. 9. The district should continue training and coaching for instructional leaders on effective feedback in changing classroom delivery of content and instructional strategies. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 192 Pupil Achievement 4.12 Assessment and Accountability Professional Standard Written policies and procedures are in place to ensure that special education processes are con- ducted pursuant to federal and state laws and that staff is provided appropriate, ongoing training to ensure proper implementation. Findings 1. The district has adopted policies and systematic procedures for identifying, screening, and assessing students, as well as planning, implementing, reviewing, and performing triennial assessments of students in special education. The Special Education Local Plan Area (SELPA) PPM has been board-adopted as the guiding document for the district. The manual provides detail on compliant practices for all special education procedures. 2. Special education staff received training on compliant and quality practices as described in the SELPA PPM noted above. Program specialists continue to work on school sites with principals and special education teachers to strengthen site-based implementation of compliant practices. 3. During the 2022-23 school year, there has been a continued focus on reducing the number of overdue IEPs. The district holds collaborative meetings with the CCEE to monitor the compliance to timelines for IEPs and the outcomes for student achievement. The executive director of special education provides a monthly update to principals and special education staff on the number of overdue IEPs districtwide and by school site. Program specialists are expected to meet with site principals prior to scheduled IEP meetings to help the principals prepare to facilitate compliant IEP meetings. Progress has been made in reducing the number of overdue IEPs, but district level special education staff described a continuous cycle of catch up and fall back behind that is an ongoing obstacle. 4. In April 2023, the district is scheduled to provide professional learning for general education instructional staff at school sites to ensure they understand their role in appropriately implementing the district-adopted special education policies and procedures. The LRE district priority includes training for special education and general education teachers and site administrators. Recommendations for Recovery 1. The district should continue to work with CDE, CCEE, and LACOE to resolve any issues of noncompliance. 2. The district should continue to closely monitor special education processes and program services to ensure they are conducted according to federal and state laws and that compliant and quality services are provided to identified students in special education in the LRE. Continue to use the SELPA PPM to support this process. Pupil Achievement 193 3. The district should continue to provide ongoing professional learning to site principals on compliant and quality special education procedures and instructional programming, including high-quality inclusive practices and ensuring that students in special education are served in the LRE. 4. The district should provide the general education instructional staff with ongoing professional learning at each school site so that they fully understand what is required in ensuring that special education processes are conducted according to federal and state laws. Include current compliance and quality issues in the professional learning content, as well as information on the general education teacher’s role in addressing those issues. Focus the professional learning content on high-quality inclusive practices and special education placement in the LRE. Standard Partially Implemented July 2013 Rating: 6 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 194 Pupil Achievement 5.1 Professional Development Professional Standard The LEA provides a continuing program of professional development to keep instructional staff, administrators, and board members updated on current issues and research pertaining to cur- riculum, instructional strategies, and student assessment. Findings 1. The district provided additional training in PLCs for all staff this year. 2. A year-long professional development plan, grounded in data, was used in the 2022-23 school year to guide the district’s banked time/early student release Tuesday professional development for instructional staff. 3. Connected to the district’s Instructional Plan, a continuum of professional learning opportunities was developed for instructional staff to increase learning on instructional practices and meet the needs of all students. 4. In addition to district-provided professional learning, many school sites provided site- specific professional learning for their staffs. 5. District administration regularly provide information to the board to update them on curriculum, instructional strategies, and student assessment and achievement. Recommendations for Recovery 1. The district should monitor participation at contracted professional learning activities and ensure that all school sites, administrators, and teachers participate in professional learning offerings. 2. The district should establish clear expectations for the outcomes of professional learning and systems of responsibility and accountability at the school-site level so that all instructional staff will participate and implement the strategies learned. 3. To ensure coherence of professional learning, the district and school sites should provide professional learning that specifically and intentionally augments and builds on previous professional learning to ensure that site processes and classroom instruction increases in quality. 4. In their given roles, all attendees should leave the professional development with clear expectations of their responsibility for implementation. Executive directors of elementary and secondary education should follow up and monitor the principals’ systemic implementation and utilize CoI to collectively analyze data at principals’ meetings. Pupil Achievement 195 5. Since there are many opportunities for professional learning, the district should continue to implement a comprehensive and cohesive plan for classroom implementation, including the CoI process utilizing instructional coaches. Special attention should be paid to ensuring that site instructional leaders are provided with professional learning to ensure these efforts lead to sustaining improved instruction at the classroom level. 6. The district should continue to regularly provide information to the board to update them on curriculum, instructional strategies, and student assessment and achievement. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 196 Pupil Achievement 5.3 Professional Development Professional Standard The LEA provides opportunities and ongoing support for teachers to collaborate on the analysis and improvement of curriculum, instruction, and use of assessment data. Findings 1. Banked time was negotiated for the 2022-23 school year, providing schools with 90 minutes of professional learning time weekly through an early student release day scheduled on Tuesday afternoons. Nineteen days were district-directed, 10 were site- directed, and 10 were Inglewood Teacher Association (ITA)-directed. 2. Initial communication regarding the use of banked time varied. As a result, a lack of coherence existed between site and district level professional learning opportunities. 3. The district has provided ongoing professional learning in the use of data gathered from various instructional platforms used by students. 4. Coaches were used to support new teachers. 5. At the high school level, schools have begun the process of gathering data and working as departments to ensure that assessment data is used to inform instructional decisions. 6. Some school sites have strong systems of support for teacher collaboration based on the use of analyzed student data. The district PLC training focused on a more effective and consistent process for teacher collaboration. Recommendations for Recovery 1. The district should continue to provide teachers with additional training and guidance to analyze student performance data through the PLC process. 2. The district should continue to develop systems of collaboration at the high school level. As an outcome of this collaboration, the district should provide professional learning and instructional supports that address any needs identified through this collaboration. 3. The district and ITA should prioritize the continuation of using banked time for professional learning. 4. The district should consider increasing district instructional coach support and ALTs at all schools based on available financial resources. 5. The district should develop internal communication outlining the use of banked time at all levels to support coherence and accountability in the system. Pupil Achievement 197 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 198 Pupil Achievement 5.5 Professional Development Professional Standard The LEA plan includes budgeted coherent professional development activities that reflect re- search-based strategies for improved student achievement and a focus on standards-based con- tent knowledge. Findings 1. The district continues to provide access to research-based professional learning opportunities. 2. The district, in conjunction with outside entities, continues to provide a variety of professional learning opportunities. 3. The district continues to focus on specific professional learning (e.g., designated ELD, PBIS) to increase student achievement. 4. The district has continued to expand the professional learning support at the elementary level and is designing professional learning to support secondary-level instruction and the specific needs of teaching adolescents and specific content areas. 5. The district has four instructional coaches to support all schools. As a result, the coaches focus on supporting new teachers. Recommendations for Recovery 1. The district should develop a comprehensive and cohesive plan to ensure that professional learning is centered on identified needs based on student data, content standards and research-based best practices for all students. 2. Using its observation tool, the district should continue to ensure that there is a coherent and measured connection between professional learning and classroom implementation using classroom observations based on the district’s focus goals. 3. Based on its LCAP goals, the district should continue to ensure that professional learning is informed by the data collected through formative assessments and monitored frequently to ensure implementation at the classroom, instructional level. 4. The district should continue to utilize the instructional coaches to support the implementation of professional development at all levels. Pupil Achievement 199 5. The district should refine and implement a cohesive plan for professional learning specific to the secondary level, needs of adolescent learners and instructional design in the content areas. This should include a distinct plan designed: • For grades 7 and 8 focused on specific needs of middle school students. • For grades 9-12 focused on teaching with a block schedule, effective engagement strategies and social-emotional development for adolescents. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 200 Pupil Achievement 6.1 Data Management/Student Information Systems Legal Standard The LEA assigns and maintains Statewide Student Identifiers and maintains all data to be report- ed to the California Longitudinal Pupil Achievement Data System (CALPADS) and the Online Public Update for Schools (OPUS) necessary to comply with No Child Left Behind reporting requirements. (EC 60900(e)) While EC 60900 (e) continues to reference the No Child Left Behind Act (NCLB), former President Obama signed the Every Student Succeeds Act (ESSA) in December 2015, reauthorizing the Federal Elementary and Secondary Education Act (ESEA) and replacing the NCLB, the 2001 reauthoriza- tion of ESEA. The ESSA took effect beginning in the 2017-18 school year. Findings 1. The IT Department is organized so that the executive director of IT is responsible for the oversight of CALPADS, Aeries, class scheduling, attendance, enrollment and class counts, and reports to the CBO. The director of educational technology reports to the CAO in Educational Services. The district has hired a database administrator who works with the executive director of IT to collect and report data. 2. For this review period, the district continued to assign the data collection positions to the school sites. Overall, site and district administration felt that enrollment and attendance is reflected more accurately, and schools have more support with this structure. 3. The district struggled to meet a CALPADS submission timeline for this review period and had to work directly with representatives from the California School Information Services (CSIS) to certify its data following the deadline. 4. A review of the California School Directory on the CDE website found information for school sites and the district is up to date. This directory is an online resource for obtaining contact and general information about schools and districts and is updated using the OPUS. Recommendations for Recovery 1. The executive director of IT and database administrator should continue to be provided with sufficient resources and assistance to ensure that the district can comply with the state requirements regarding maintaining statewide student identifiers and to work with the state regarding CALPADS and OPUS. 2. The district should prioritize meeting all CALPADS reporting deadlines and establish a clear system that includes expectations, procedures and processes to accurately report data in a timely way. Pupil Achievement 201 3. The district should continue to provide monthly training on the CALPADS processes and procedures manual to those responsible for entering data at school sites and other specialized departments and continue to concentrate on the quality of data entered into Aeries. Continue to monitor the implementation of processes at the school sites and provide additional training for any area identified as problematic. 4. The district should hold site administration accountable for reviewing and analyzing data specific to their school site. This is an additional layer of review for ensuring the accuracy of the data. The district should regularly examine what data site administrators should review and the processes to follow if the data does not appear accurate. 5. The district should continue to ensure that the information in OPUS accurately reflects administration any time changes are made. Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 2 July 2017 Rating: 4 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 202 Pupil Achievement Table of Pupil Achievement Ratings Pupil Achievement 203 204 Pupil Achievement July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating LEGAL STANDARD – PLANNING PROCESSES Omitted Categorical and per SB 98, compensatory program Section 1.1 2 2 5 6 6 7 7 5 6 6 funds supplement and do 102 due to not supplant services and COVID-19 materials to be provided by pandemic. the LEA. (20 USC 6321) LEGAL STANDARD – PLANNING PROCESSES Omitted Each school has a school per SB 98, site council, comprised Section 1.2 of teachers, parents, 2 2 4 4 5 5 5 5 5 6 102 due to principal and students, COVID-19 that is actively engaged pandemic. in school planning. (EC 52050-52075) PROFESSIONAL STANDARD – PLANNING PROCESSES The LEA’s policies, Omitted culture and practices per SB 98, reflect a commitment to Section 1.4 2 1 2 2 2 2 3 3 4 5 implementing systemic 102 due to reform, innovative COVID-19 leadership, and high pandemic. expectations to improve student achievement and learning. PROFESSIONAL STANDARD – PLANNING PROCESSES The LEA has fiscal policies Omitted and a fiscal resource per SB 98, allocation plan that are Section 1.5 aligned with measurable 1 1 1 3 3 3 3 3 4 5 102 due to student achievement COVID-19 outcomes and instructional pandemic. goals including, but not limited to, the Essential Program Components. (Revised DAIT) PROFESSIONAL STANDARD – PLANNING PROCESSES The LEA has policies to fully implement the State Board of Education- adopted Essential Omitted Program Components per SB 98, for Instructional Section 1.6 Success. These include 2 1 2 3 3 5 4 3 3 4 102 due to implementation of COVID-19 instructional materials, pandemic. intervention programs, aligned assessments, appropriate use of pacing and instructional time, and alignment of categorical programs and instructional support. PROFESSIONAL STANDARD – PLANNING PROCESSES The LEA provides and supports the use of Omitted information systems and per SB 98, technology to manage Section 1.8 3 1 3 3 4 4 4 4 4 5 student data, and provides 102 due to professional development COVID-19 to site staff on effectively pandemic. analyzing and applying data to improve student learning and achievement. (DAIT) Pupil Achievement 205 July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – PLANNING PROCESSES Omitted The LEA holds teachers, per SB 98, site administrators, Section 1.9 1 1 1 2 2 2 2 2 3 4 and LEA personnel 102 due to accountable for student COVID-19 achievement through pandemic. evaluations and professional development. LEGAL STANDARD – CURRICULUM The LEA provides and fully implements SBE-adopted and standards-based (or Omitted aligned for secondary) per SB 98, instructional textbooks and Section 2.1 materials for all students, 4 2 3 3 3 3 2 2 3 4 102 due to including intervention in COVID-19 reading/language arts and pandemic. mathematics, and support for students failing to demonstrate proficiency in history, social studies, and science. (EC 60119, DAIT) PROFESSIONAL STANDARD – CURRICULUM The LEA has planned, adopted and implemented Omitted an academic program per SB 98, based on California Section 2.3 4 2 3 3 3 3 3 3 3 4 content standards, 102 due to frameworks, and SBE- COVID-19 adopted/aligned materials, pandemic. and articulated it to curriculum, instruction, and assessments in the LEA plan. (DAIT) PROFESSIONAL STANDARD – CURRICULUM Omitted The LEA has developed per SB 98, and implemented common Section 2.4 3 1 2 3 3 3 3 3 3 4 assessments to assess 102 due to strengths and weaknesses COVID-19 of the instructional pandemic. program to guide curriculum development. PROFESSIONAL STANDARD – CURRICULUM Omitted The LEA has adopted per SB 98, a plan for integrating Section 2.5 3 1 1 3 3 3 2 3 3 4 technology into curriculum 102 due to and instruction at all grade COVID-19 levels to help students pandemic. meet or exceed state standards and local goals. LEGAL STANDARD – INSTRUCTIONAL STRATEGIES The LEA provides equal access to educational opportunities to all Omitted students regardless per SB 98, of race, gender, Section 3.1 socioeconomic standing, 3 2 3 3 3 4 4 5 6 6 102 due to and other factors. The COVID-19 LEA’s policies, practices, pandemic. and staff demonstrate a commitment to equally serving the needs and interests of all students, parents, and family members. (EC 51007) 206 Pupil Achievement July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating LEGAL STANDARD – INSTRUCTIONAL STRATEGIES The LEA provides students Omitted with the necessary courses per SB 98, to meet the high school Section 3.6 graduation requirements. 5 7 9 9 10 10 10 10 10 10 102 due to (EC 51225.3) The LEA COVID-19 provides access and pandemic. support for all students to complete UC and CSU required courses (A-G requirement). LEGAL STANDARD – INSTRUCTIONAL Omitted STRATEGIES per SB 98, The LEA provides an Section 3.7 alternative means for 5 7 8 9 10 10 10 10 10 10 102 due to students to complete the COVID-19 prescribed course of study pandemic. required for high school graduation. (EC 51225.3) LEGAL STANDARD – INSTRUCTIONAL STRATEGIES The LEA has adopted Omitted systematic procedures for per SB 98, identification, screening, Section 3.10 2 1 3 2 3 3 3 3 5 5 referral, assessment, 102 due to planning, implementation, COVID-19 review, and triennial pandemic. assessment of students with special needs. (EC 56301) LEGAL STANDARD – INSTRUCTIONAL STRATEGIES Programs for special education students meet the least restrictive Omitted environment provision of per SB 98, the law and the quality Section 3.12 6 2 2 2 3 3 3 3 4 4 criteria and goals set 102 due to forth by the California COVID-19 Department of Education pandemic. and the Individuals with Disabilities Education Act. (EC 56000, EC 56040.1, 20 USC Sec. 1400 et. seq.) PROFESSIONAL STANDARD – Omitted INSTRUCTIONAL per SB 98, STRATEGIES Section 3.13 2 1 1 3 3 3 2 2 2 4 Students are engaged in 102 due to learning, and they are able COVID-19 to demonstrate and apply pandemic. their knowledge and skills. PROFESSIONAL STANDARD – INSTRUCTIONAL STRATEGIES The LEA optimizes Omitted opportunities for all per SB 98, students, including Section 3.15 4 2 2 3 3 4 4 3 5 5 underperforming students, 102 due to students with disabilities, COVID-19 and English language pandemic. learners, to access appropriate instruction and standards-based curriculum. (DAIT) Pupil Achievement 207 July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – INSTRUCTIONAL STRATEGIES Omitted The LEA makes ongoing per SB 98, use of a variety of Section 3.16 2 1 1 2 2 2 2 2 2 4 assessment systems 102 due to to appropriately place COVID-19 students at grade level, pandemic. and in intervention and other special support programs. (DAIT) PROFESSIONAL STANDARD – INSTRUCTIONAL Omitted STRATEGIES per SB 98, Programs for English Section 3.17 language learners comply 2 2 2 2 2 3 4 3 5 5 102 due to with state and federal COVID-19 regulations and meet the pandemic. quality criteria set forth by the California Department of Education. PROFESSIONAL STANDARD – INSTRUCTIONAL STRATEGIES Omitted The LEA employs per SB 98, specialists for improving Section 3.18 3 1 3 4 4 4 4 5 5 5 student learning, including 102 due to content experts and COVID-19 specialists with skills pandemic. to assist students with specific instructional needs. PROFESSIONAL STANDARD – INSTRUCTIONAL STRATEGIES Omitted The LEA offers a per SB 98, multiyear, comprehensive Section 3.22 high school program of 5 5 3 3 3 4 4 5 7 8 102 due to integrated academic and COVID-19 technical study that is pandemic. organized around a broad theme, interest area, or industry sector. (EC 52372.5, EC 51226) PROFESSIONAL STANDARD – ASSESSMENT AND ACCOUNTABILITY Omitted The LEA has developed per SB 98, summative and frequent Section 4.3 3 1 2 3 3 3 3 3 3 5 common formative 102 due to assessments that inform COVID-19 and direct instructional pandemic. practices as part of an ongoing process of continuous improvement. PROFESSIONAL STANDARD – ASSESSMENT AND ACCOUNTABILITY Omitted The LEA provides an per SB 98, accurate and timely Section 4.4 4 1 3 4 5 5 5 5 5 5 school-level assessment 102 due to and data system as COVID-19 needed by teachers pandemic. and administrators for instructional decision- making and monitoring. 208 Pupil Achievement July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – ASSESSMENT AND ACCOUNTABILITY School staff assesses Omitted all students to per SB 98, determine students’ Section 4.5 needs, and whether 3 2 3 3 3 3 3 3 3 4 102 due to students require close COVID-19 monitoring, differentiated pandemic. instruction, additional targeted assessment, specific research based intervention, or acceleration. PROFESSIONAL STANDARD – ASSESSMENT AND Omitted ACCOUNTABILITY per SB 98, The LEA and school site Section 4.10 4 2 3 4 4 4 4 3 3 4 administration monitor 102 due to fidelity of program COVID-19 implementation in the pandemic. delivery of content and instructional strategies. PROFESSIONAL STANDARD – ASSESSMENT AND ACCOUNTABILITY Written policies and Omitted procedures are in place per SB 98, to ensure that special Section 4.12 6 2 3 2 3 3 3 3 4 5 education processes are 102 due to conducted pursuant to COVID-19 federal and state laws pandemic. and that staff is provided appropriate, ongoing training to ensure proper implementation. PROFESSIONAL STANDARD – PROFESSIONAL DEVELOPMENT The LEA provides a Omitted continuing program of per SB 98, professional development Section 5.1 to keep instructional 4 3 4 4 4 4 4 5 5 6 102 due to staff, administrators, and COVID-19 board members updated pandemic. on current issues and research pertaining to curriculum, instructional strategies, and student assessment. PROFESSIONAL STANDARD – PROFESSIONAL Omitted DEVELOPMENT per SB 98, The LEA provides Section 5.3 opportunities and ongoing 3 1 1 1 2 2 2 3 4 5 102 due to support for teachers to COVID-19 collaborate on the analysis pandemic. and improvement of curriculum, instruction, and use of assessment data. Pupil Achievement 209 July July July July July July July July July July July Pupil Achievement 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating: Rating: Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – PROFESSIONAL DEVELOPMENT Omitted The LEA plan includes per SB 98, budgeted coherent Section 5.5 professional development 3 2 2 3 3 3 3 3 4 5 102 due to activities that reflect COVID-19 research-based strategies pandemic. for improved student achievement and a focus on standards-based content knowledge. LEGAL STANDARD – DATA MANAGEMENT/ STUDENT INFORMATION SYSTEMS The LEA assigns and maintains Statewide Omitted Student Identifiers and per SB 98, maintains all data to be Section 6.1 reported to the California 4 3 4 2 4 5 5 5 6 5 102 due to Pupil Achievement COVID-19 Longitudinal Data System pandemic. (CALPADS) and the Online Public Update for Schools (OPUS) necessary to comply with No Child Left Behind reporting requirements. (EC 60900(e) Collective Average Rating 3.23 2.03 2.87 3.32 3.68 3.94 3.87 — 3.87 4.48 5.19 210 Pupil Achievement Financial Management Financial Management 211 212 Financial Management 1.1 Internal Control Environment Professional Standard All board members and management personnel set the tone and establish the environment, exhibiting high integrity and ethical values in carrying out their responsibilities and directing the work of others. Appropriate measures are implemented to discourage and detect fraud. (State- ments on Auditing Standards (SAS) 55, SAS 78, SAS 82: Treadway Commission) Findings 1. Board policies and administrative regulations are a vital component of internal control and provide the guidelines and directives necessary for a district and its personnel to operate. The district subscribes to the CSBA’s GAMUT online services, allowing board policies and administrative regulations adopted by the district to be accessed from a link on the district’s website. The district has adopted several BBs, policies, administrative regulations, and exhibits that demonstrate, support and communicate its intent to foster a behavioral culture of high integrity and ethical values including: • BB 9270-Conflict of Interest, revised on April 17, 2019. This bylaw outlines the requirements of governing board members and designated employees to annually disclose any conflict of interest that would preclude them from participating in any district-related decision that includes that interest. • BP and AR 1313.01-Civility Policy, demonstrates in part the intent of the administration to set the tone and establish a foundation for an environment that, as stated in the policy, “promotes mutual respect, civility and orderly conduct among district employees, parents/guardians and the public.” The policy and regulation were previously numbered 1310.1, and FCMAT is unclear how or when the number changed. The last reviewed date remains unchanged from February 5, 2015, the original adopted date. The referenced related exhibit numbers did not change, and BP Exhibit 1310.1E(2)-Withdrawal of Consent, is not available on the district's website. • BP and AR 3400-Management of District Assets/Accounts, adopted on August 4, 2014, recognize the importance of developing a system of internal control procedures that include separation of duties and fraud prevention, specifically in the areas related to recording or reporting transactions, which would include purchasing, receiving, and payment functions. BPs 3314-Payment for Goods and Services, updated April 17, 2019, and 3314.2-Revolving Funds, adopted August 4, 2014, also describe the board’s fiduciary duties to manage and safeguard district assets and resources effectively. • BPs 4119.21, 4219.21 and 4319.21-Professional Standards, and their corresponding exhibits, further support the district’s expectations of employees to conduct themselves ethically and appropriately. These Financial Management 213 policies encourage district employees to “accept as guiding principles the professional standards and codes of ethics adopted by educational or professional associations to which they may belong.” Inappropriate employee conduct is also defined within these policies. BP Exhibit 4219.21 was last revised April 22, 2020; the other board policies noted were last updated August 4, 2014. The district has established a Board Policy Committee assigned the duties of review- ing policy updates as determined to be necessary and/or recommended by the GAMUT subscription service. The committee has most recently been led by the COO. With the district’s elimination of the COO position and subsequent employee turnover, the com- mittee has had limited activity with only two policy updates during this review period; the district has yet to identify another staff member to lead the committee. The district sends email communication to all staff identifying all new and amended board policies and ad- ministrative regulations approved by the county administrator/board and provides a link to the district website so staff can easily access and review changes. 2. Board members and employees designated in the district’s Conflict of Interest Code (BB 9270) are required by GC 87500 to annually file a statement of economic interests/ Form 700 to disclose any assets and income that may be materially affected by official actions. Exhibit 9270 was revised December 14, 2022. Inconsistencies continue between designated positions in the exhibit and the organizational charts provided for this review period, including variations in titles and the omission or inclusion of certain administrative positions (e.g., the deputy chief maintenance and operations officer and the executive director of risk management are not included as designated positions on the revised exhibit, although both positions existed prior to December 2022). A best practice is to establish a list of generalized categories (for example, all senior execu- tive director, executive director, director, and principal positions), but careful consideration should be given to developing this list to ensure all appropriate positions are included. Ad- ministrative positions with purchase authority are customarily included as designated posi- tions. Modifying the list to include generalized categories that fit a more fluid organizational structure will improve clarity in positions required to submit Form 700. 3. A list of specific employees, board members and consultants in designated disclosure category positions should be maintained to ensure forms are collected from all individuals required to file Form 700. The district’s Conflict of Interest Form 700 Roster Tracking System documenting submissions for 2022-23 does not include disclosure categories, and is missing some designated positions, such as the director of human resources. FCMAT was provided with completed Form 700s collected for January 1, 2022 through De- cember 31, 2022. FCMAT’s review of the forms provided continue to identify deficiencies. FCMAT noted instances of forms not submitted, forms not dated or signed, or forms with the incorrect jurisdiction selected. BB 9270 and GC Section 87302 provide for filing Form 700 annually and within 30 days of assumption of office and within 30 days of leaving office. The district does not have a process 214 Financial Management that ensures all employees assuming or exiting positions designated as required to complete Form 700s, do so. Form 700s were not provided to FCMAT for several appointments to des- ignated positions during the period under review. In addition, while several positions were vacated during the time frame under review, no Form 700s were provided for those staff members. 4. The district contracted with an independent accounting firm to conduct the required annual audit for the 2021-22 fiscal year. The audit report cites significant deficiencies in internal control in several functional areas of business practice that leave the district’s assets susceptible to misstatement, theft, or fraud. Although the district had greatly reduced the number of audit findings over the past several years, it continues to experience new audit findings classified as material weaknesses or significant internal control deficiencies. The 2021-22 fiscal year audit contained 17 audit findings, an increase of nine from the prior year, and six of which were repeated or partially repeated from the prior year. Four of the new audit findings indicated disallowable ADA, potentially resulting in funding loss. 5. Formal operational policies and procedures help establish protocols for completing, reviewing, and overseeing the business office’s routine functions. When properly designed, implemented, and followed, written procedures improve the effectiveness of the internal control structure and offer reasonable assurance that the risk of fraud, misappropriation of funds or other illegal acts is reduced and that occurrences will be detected promptly. The district has several departmental procedural manuals that provide written standards regarding processes for primary departmental duties. The procedures in these manuals support the basic processes for administrators and staff to follow, but are not standard operating procedures for the routine duties of each departmental employee’s desk. Interviews with staff indicated that some business office personnel have resumed efforts to establish and update operational procedures for the Business Services Department. How- ever, there is no established process or timelines for reviewing and updating procedures as changes within the department take place. Written processes and procedures for routine business activities are the foundation of strong internal controls, but will be ineffective un- less implemented in practice, monitored, evaluated, and enforced. Some staff reported that executive management continues to override established proce- dures and school site and department administrators are not consistently held accountable to established board policies, administrative regulations, and operational procedures. Man- agement override of formally established policies and procedures weakens the district’s system of internal control and increases the risk of misappropriation of funds. 6. Establishing and maintaining a fraud prevention program is essential to fraud deterrence. Tips from employees, either by reporting to supervisors or through use of an anonymous tip hotline, are common methods of detecting fraud. These methods are typically most effective when employees have access to, and are regularly made aware of, an anonymous tip line. The mere existence of such mechanisms is a highly effective fraud prevention technique. Financial Management 215 The district does not have a formalized fraud prevention program. A program is offered through the district’s risk management provider called WeTip that promotes a hotline for anonymous reporting of tips related to crimes such as workers’ compensation fraud, dis- crimination, harassment, threats, safety violations, burglary, and weapons. This program helps increase awareness of fraud prevention. However, interviews with district and site per- sonnel clearly indicated the program is not actively promoted throughout the district, which has no other formalized fraud prevention and/or detection program. 7. The district has established annual employee notifications that incorporate sections addressing the district’s Code of Conduct and Code of Ethics. The annual notifications are disseminated to all employees, including substitutes, and require each employee to complete an acknowledgement of receipt each year. The notifications communicate that “The Board of Education expects district employees to maintain the highest ethical standards, exhibit professional behavior, follow district policies and regulations, abide by state and federal laws, and exercise good judgment…” All employee handbooks include a section that speaks to the district’s Code of Ethics. 8. Communication, training and routine monitoring of processes and procedures are essential to ensure control activities are successful and effective. During the review period, the district experienced turnover in key positions in the HR, Student Support Services, and Business Services departments, including all three fiscal leadership positions, the CBO, senior executive director of fiscal services, and director of fiscal services. This turnover, especially within the Business Services Department, challenges the district’s ability to maintain strong systems of internal control and communication; consequently, district staff reported some issues working with the Business Services Department during this review period and some staff do not respond timely to requests for information. However, some business office staff members meet regularly with staff from other departments and school sites. Meetings with the Business Services, HR and Risk Management departments’ staff are held routinely or as needed to collaborate and discuss issues that cross departmental functions. Some business office personnel report progress towards evaluating and updating operational processes and procedures, but this practice is inconsistent across all disciplines. At the time of FCMAT’s fieldwork, the district did not have a functioning audit commit- tee. There were plans for a committee to be established and start meeting in March 2022, but the district did not implement them. The district appointed an advisory board mem- ber to the audit committee at the December 14, 2022 board meeting; however no meetings had been held at the time of FCMAT’s fieldwork. Establishing an audit committee can improve the district’s system of internal controls by fostering an environment and culture that clearly communicates that fraud and other illegal practices will not be tolerated, and that all allegations will be investigated. External audits and reports, internal reviews, or investigations can generate opportunities for growth and allow responsible staff to identify specific elements underlying the areas of concern and develop a collaborative plan to implement best practices. An audit committee can also serve as a body for monitoring the business office’s progress on the corrective ac- tions taken to address audit findings that identify weaknesses in internal controls, present- ing opportunities for fraud, misappropriation of funds or other illegal practices. 216 Financial Management Recommendations for Recovery 1. The district should continue to routinely review and update board policies and administrative regulations and identify a staff member to lead the Board Policy Committee. Department administration and management level staff should continue to actively contribute to the review and proposed revision of policies and regulations specific to their span of authority. The district should continue to modify standard language provided by CSBA’s GAMUT policy service, tailoring each policy to the specifics of the district and removing all nonapplicable language. Ensure all exhibits referenced in policies and regulations are accessible on the district’s website. 2. The district should ensure the designated positions listed in Exhibit 9270 Board Bylaws, Conflict of Interest Code, and assigned disclosure categories accurately reflect positions maintained by the district. Where possible, designated positions should reflect generalized categories, such as “executive directors” and “directors,” rather than specific positions. Designated positions should align with the organization’s administrative structure presented in its organizational charts. 3. All designated positions should be required to complete Form 700 upon hire, annually and upon separation of employment. The district should establish a system that accounts for the completion and collection of these forms. The district should establish and routinely update a list of designated positions identified in Exhibit 9270 as responsible for completing Form 700. The list should identify all individual(s) employed in those positions during the calendar year and include their dates of hire/assignment and dates of separation of duty. This list should be updated any time position titles change and when staffing changes take place. Form 700 should be completed as part of the hiring and separation from employment processes managed by the HR Department, then forwarded to the staff member responsible for collection. 4. The district should ensure the employee(s) assigned responsibility for collecting the Form 700s are properly trained on the rules of submission, including the time frame covered by the forms, who should complete the form, and how to review submissions to ensure they are complete, signed and dated, and the selected jurisdiction is correct. 5. The district should review external audits, reports, and reviews with applicable staff to identify the specific elements underlying the areas of concern and develop a collaborative plan to implement best practices and resolve the audit findings. 6. The district should ensure operational procedures are implemented and monitored to make certain the district operates effectively and efficiently and that the established system of internal control adequately prevents, discourages, and detects fraud and safeguards district assets. The district should continue efforts in updating the comprehensive policies and procedures manual previously established by the Business Services Department. Employee desk manuals or standard operating procedures should be developed and updated at least annually. During this process, all components of internal control should be evaluated, deficiencies should be identified, and procedures should be established to mitigate deficiencies in high-risk areas. Financial Management 217 7. The district should routinely review, update and monitor operational procedures and provide staff training. The operational procedures should be followed by all employees and should not be overridden by management. 8. The district should implement a fraud prevention program and ensure that all district and school site staff are familiar with it. Written procedures should be established for retrieving the information reported, including a protocol for determining the level of investigation warranted; a means of determining who should perform an investigation; and procedures for reporting the results. The district should consider adding this to the annual policy review process. 9. Principals, office managers and other school site/department representatives who attend district and other informational meetings and/or are the primary recipient of communications regarding district-established policies and procedures should relay the information to all affected positions at their school site/department as soon as possible after receiving that information. 10. The district should establish an audit committee as another level of oversight to help ensure proper operations and adequate follow-up to internal reviews and independent audit findings. Meeting agendas and minutes should be prepared and maintained. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 218 Financial Management 1.3 Internal Control Environment Professional Standard The organizational structure clearly identifies key areas of authority and responsibility. Reporting lines in each area are clearly identified and logical. (SAS 55, SAS 78) Findings 1. The district maintains a districtwide organizational chart that as of January 25, 2023 outlines four divisions under the county administrator: the CBO, chief HR officer, CAO, and chief of police. As of March 2023, the district website still showed the previous chart dated January 26, 2022. The former COO division responsibilities have been organized under an executive director of student support services reporting directly to the county administrator. Each division also maintains separate organizational charts further identifying lines of authority. The charts identify established, but otherwise vacant positions. 2. The organization’s continual restructuring has created confusion for staff regarding lines of authority and hinders progress towards achieving organization wide goals. In some instances, the lines of authority on the organizational charts are inaccurate. For example, on the districtwide organizational chart dated January 25, 2023, the director of fiscal services is shown as having direct line authority over the director of food services who has direct line authority over the executive director of information technology. However, interviews and the business services organizational chart indicate the CBO supervises the executive director of information technology and the director of food services. In another example, the director of educational technology is shown as reporting to two different division leaders: 1) The CAO in the educational services organizational chart dated January 13, 2023, and 2) The CBO in the business services organizational chart dated August 16, 2022. Interviews and the districtwide organizational chart indicate the director of educational technology reports to the CAO. 3. The district also identifies departmental leadership and support staff on its website. Inconsistencies in positions and/or position titles were noted when compared to organizational charts. In addition, individuals no longer employed with the district continue to be listed on the website. This creates confusion about the official authorized positions and/or staff members holding these positions. 4. District administrators, Business Services Department staff and school site administration and staff indicate they are aware of changes in district administration and understand who handles which tasks in the district office. School site staff reported being made aware of organizational changes as they occur. Interviews with school site staff members indicated that if they do not know who handles a specific matter, they can contact at least one source in the business office to be redirected to the appropriate individual. Financial Management 219 Recommendations for Recovery 1. The district should continue to update the districtwide and division/department organi- zational charts when necessary to reflect staffing changes and to identify all management and district support staff positions under each division/department ensuring that lines of reporting are clearly identifiable and accurate. All organizational charts should include the date they are approved and/or revised by the county administrator/board. 2. The district should distribute organizational charts to all employees after each revision to help ensure staff understands changes as they take place and to communicate where to direct their questions. 3. Departmental leadership should communicate changes to reporting lines of authority when vacancies occur, even when temporary, and actively enforce the chain of command by directing questions through the appropriate department channels. 4. The district should establish a process that ensures its website is updated timely when changes in organizational structure, positions, titles, and/or staff are formally approved. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 3 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 5 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 220 Financial Management 2.1 Inter- and Intradepartmental Communications Professional Standard The Business and Operational departments communicate regularly with internal staff and all user departments on their responsibilities for accounting procedures and internal controls. Communications are written when they affect many staff or user groups, are issues of importance, and/or reflect a change in procedures. Procedure manuals are developed. The Business and Operational departments are responsive to user department needs. Findings 1. The district office administration continues to work to improve cohesive communications between the Business Services and Operational departments and other departments and school sites. However, interviews indicated that communication between some business office staff members has been strained during this review period, and some staff do not respond timely to requests for information from department and site staff. Rather than implement a standard response time for email and telephone messages and hold business office staff accountable to follow it, the district has established other procedures. For example, a payroll inquiry form was developed, and district employees must complete it if they have payroll questions instead of simply calling or emailing the HR Department or business office. 2. The CBO has been with the district since June 2022 and oversees the Fiscal Services, Facilities Planning and Construction, Food Services, IT, and the Maintenance, Operations and Transportation (MOT) departments. During this review period, an executive director of risk management position was created, and Risk Management was reassigned and is now overseen by the CBO. At the time of FCMAT’s fieldwork, all six of the department head positions were filled, four during this review period by a promoted or newly hired employee. Additionally, four of the 15 positions in the business office were filled and/or filled more than once during this review period, and there were two vacant positions at the time of FCMAT’s fieldwork. 3. The CBO, and oftentimes other business office staff members, attend the districtwide principals’ meetings monthly. Various staff members from the Business Services and Educational Services departments conduct monthly online meetings with each principal to discuss budgets and staffing, and interviews indicated that these meetings have been well received. During this review period, a monthly budget meeting schedule was also developed for department leaders, and the schedule includes the CBO as one of the business office representatives. Based on the information provided, the CBO does not appear to routinely attend the online monthly meetings with each principal and department leader. It would be beneficial for the CBO to schedule routine meetings, for example quarterly or biannually, with each school and department leader to discuss their budgets and other responsibilities related to procedures for areas such as accounting, internal controls, purchasing and payroll. Financial Management 221 4. Office managers and administrative secretaries continue to have monthly meetings, where various district departments, including Business Services, share information regarding departmental processes and procedures. The 2021-22 and 2022-23 meeting calendars indicate that the meetings are conducted virtually and that they are mandatory; however, only one meeting attendance roster was provided to FCMAT, and it shows that several invitees were not planning to attend. 5. The senior executive director of fiscal services has scheduled weekly meetings with business office managers, and the senior executive director and/or CBO meet periodically with various groups in the business office. Interviews indicated that a few meetings have been conducted with all the business office staff during this review period; however, routine business office staff meetings have not yet been scheduled. 6. Interviews with staff indicated that interdepartmental communications between the Business Services and HR departments have improved during this review period. Leadership continues to work to assess interdependent activities and procedures, evaluate their effectiveness and revise existing or establish new procedures. In addition, applicable staff members from the two departments meet routinely to discuss various topics such as employee leaves, payroll issues, and position control. 7. The business office uses a shared drive where department staff members can access documents that affect duties between their positions and various other business office documents. 8. The Inglewood Unified School District Administrative Handbook is listed as a link on the HR Department website; however, FCMAT could not access it and received a message stating, “This site can’t be reached.” The handbook had previously included a section for the Business Services Department, which had numerous links to items such as the districtwide directory with administrator and support staff names and contact information, procedures, and forms. Some of this information is now posted on the district’s website under various Business Services and other headings. The website contains business office staff names, contact information and major job duties as well as numerous reports and forms of interest to districtwide staff and those affected. However, it does not include all the processes and procedures regarding site and department business functions, and some of the information, such as staff names shown under Business Services Staff Contact Information on the Business Services page, is outdated. 9. The business office has continued to develop the Business Services Division Procedure Manual, which includes sections for accounting, budget, payroll and purchasing. The unfinished manual is reportedly available to business office staff on the district’s shared drive, but it is unclear if this procedure manual will also serve as a desk manual for each business office position. Various other procedure documents were also provided to FCMAT (e.g., draft Purchasing Department SOP 2022-2023 and Monthly Absence Report Reconciliation), but it is unclear if they will be incorporated in the Business Services Division Procedure Manual. 222 Financial Management Recommendations for Recovery 1. The district should continue to develop and enhance efforts to establish a systematic pro- cess for effective communication between the Business Services and Operational depart- ments and between business office departments and school sites. 2. The district should establish a districtwide standard for responding to email and telephone messages, such as one business day, and hold all employees accountable for meeting it. 3. The CBO should schedule and conduct meetings with each principal and division/de- partment leader to review his or her budget and responsibilities for internal controls and operational procedures. 4. The district should continue making the monthly office manager and administrative sec- retary meetings mandatory and should hold all applicable staff accountable for attending. 5. The district should ensure that business office staff meetings are routinely scheduled and conducted. 6. The Business Services and HR departments’ staff should continue to meet to resolve is- sues and reconcile the position control system and ensure it is consistently and accurately maintained. 7. The district should publish a handbook that includes business office processes and pro- cedures for school sites and departments in a centralized online source. The handbook should be reviewed and updated at least annually. 8. The district should continue to establish formal written procedures for the business office and ensure that desk manuals are developed and include current policies and step-by-step procedures for all business office functions. Manuals should be reviewed and updated at least annually and as changes occur and should be posted in a centralized online source. Financial Management 223 Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 2 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 224 Financial Management 2.3 Inter- and Intradepartmental Communications Professional Standard The board is engaged in understanding the fiscal status of the LEA, for the current and two subsequent fiscal years. The board prioritizes LEA fiscal issues, and expects reports to align the LEA’s financial performance with its goals and objectives. Agenda items associated with business and fiscal issues are discussed at board meetings, with questions asked until understanding is reached prior to any action. Findings 1. All seats on the district’s five-member elected board, referred to as an advisory board, are filled. Four of the advisory board members have completed the CSBA Masters in Governance program, and information provided by the district indicates that the board member who was newly elected in 2022 plans to register for the program. The program includes courses in the following areas: Foundations of Effective Governance/Setting Direction, Student Learning & Achievement/Policy & Judicial Review, School Finance, Human Resources/Collective Bargaining, and Community Relations & Advocacy/ Governance Integration. 2. A review of the agendas and minutes posted on the district’s website indicates 22 board meetings occurred from February 2022 through January 2023; in addition to regular meetings, these included four special board meetings and three board workshops. Minutes show that three or more members were present at all the meetings except for the December 13, 2022 board workshop, at which two members were present. It is essential for the advisory board members to regularly attend meetings to gain a broader understanding of their role and the district’s fiscal matters. 3. Interviews with district administrators and advisory board members indicated that the advisory board members are engaged and ask questions at meetings. Board meeting minutes indicated that the board provides comments about items such as the budget, interim and unaudited actuals reports and cash flow during the reports/presentations portion of the agenda. 4. Many of the district’s routine fiscal matters such as approval/ratification of purchase orders, approval of vendor/payroll warrant resolutions, approval of travel expenditures/ conference requests, and numerous contracts and consultant agreements are presented at regular board meetings. During this review period, items regarding the district’s fiscal condition, including the budget adoption, interim reports and unaudited actuals, were also presented at regular, rather than special, board meetings. These items should continue to be on regular board meeting agendas since dates for these meetings are typically determined each December and allow advisory board members and the public more time to schedule attendance and review agendas and backup materials. Items on the district’s fiscal condition are listed as consent calendar/action items on the board meeting agendas, Financial Management 225 and items such as the budget, interim reports and unaudited actuals are also included on the reports/presentations portion of the agenda preceding county administrator action on the issue. 5. Interviews continue to indicate that board agendas and backup materials are provided at least 72 hours before each regular board meeting. During this review period, the district started providing the materials on Fridays, rather than on Sundays, before regular board meetings. Board agendas and materials, including budget documents and the assumptions narrative for each reporting period, should continue to be provided to advisory board members before board meetings and with sufficient time to review documentation, formulate questions and prepare for discussion. Budget issues are discussed in further detail in the budget sections of this report. 6. Board meeting agendas and minutes are available through links on the district website. Supporting documentation, including that associated with many business and fiscal issues, is also available through links embedded in each agenda. FCMAT’s review of agendas and minutes for meetings conducted from February 2022 through January 2023 found that information regarding the rationale and financial impact of items is included on the board agendas. 7. The December 14, 2022 board meeting minutes included designations of board representatives to serve on district committees; one advisory board member was appointed to continue to serve on the Budget Advisory Committee. The 2022 Budget Advisory Committee member list included two advisory board members. However, district documents show that no committee meetings were conducted during this review period, and the advisory board appointee did not provide updates about the Budget Advisory Committee at any board meetings. 8. The district conducted three board workshops during this review period, which included information about the district’s strategic plan, college and career readiness, and a High Level Review of the Budget–First Interim. Supporting documentation for the budget review was not included with the December 13, 2022 board workshop agenda, so it is unknown what was presented and discussed at the meeting. The meeting minutes indicate that only two advisory board members attended the workshop and that it lasted for approximately one hour. Although district staff provide budget presentations to the county administrator/board at regular board meetings, these presentations are usually brief and specific to the budget that is presented for approval at each given reporting period. Budget study sessions/workshops typically provide more global as well as detailed information about the entire budget process, such as how the budget is structured and developed, and budget terminology. These sessions/workshops also typically provide more time for the board to ask questions regarding the district’s budget and related processes. Recommendations for Recovery 1. New advisory board members should initially receive, and all existing advisory board members should continue to periodically receive, governance and school finance training. 226 Financial Management 2. Advisory board members should attend all board meetings and actively demonstrate a desire to learn about all fiscal matters presented. 3. Items regarding the district’s fiscal condition, such as the budget adoption, interim reports and unaudited actuals, should continue to be included on regular board meeting agendas. 4. The district should continue to provide board agendas and materials to advisory board members before board meetings as required by law and ensure that materials are provided with sufficient time for review and preparation for discussion. 5. The Budget Advisory Committee should continue to include representatives from the advisory board, and committee meetings should be routinely scheduled and conducted. 6. The district should routinely conduct, and the advisory board members should attend budget study sessions/workshops to learn more about the district’s budget, financial condition and fiscal decisions. Standard Fully Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 5 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 8 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 227 3.1 Staff Professional Development Professional Standard The LEA has developed and uses a professional development plan for training business staff. The plan includes the input of business office supervisors and managers, and identifies appropriate training programs. Each staff member and management employee has a plan designed to meet their individual professional development needs. Findings 1. The district has not completed a formal staff development plan for the business office. However, interviews indicated that the CBO and senior executive director of fiscal services are working with staff to develop a plan for each business office staff member. The district provided a 2022-23 staff training plan spreadsheet, which includes most of the business office staff and managers and shows trainings attended through December 2022 and those planned for some individuals through May 2023. 1. In a prior review period, the business office developed the Inglewood Unified Professional Development Plan Business Services Department template, which states “... Business Services will ask all management employees to work with their supervisor or administrator to develop a Professional Development Plan.” Although the template indicates it is for management employees, it was provided to FCMAT for three business office staff members and managers during this review period. The plans include the training activity and date and state whether the training has been completed; the plans also include desired training. A review of these documents showed some inconsistencies in training activities and dates compared to the 2022-23 staff training plan spreadsheet. 2. BP 4331 (adopted August 4, 2014) states the following: The Superintendent or designee shall develop a plan for administrator support and development activities based on a systematic assessment of the needs of district students and staff and aligned to the district’s vision and goals. This policy addresses staff development for management, supervisory and confidential personnel. AR 4331 (adopted August 4, 2014) identifies the following as potential methods of professional development: • Professional education conferences or committee meetings • Courses offered by institutions of higher education • Workshops offered by the district, county office of education, or state • Small-group activities • Self-directed learning 228 Financial Management • Observation of other schools • Follow-up activities that help staff implement newly acquired skills 3. BP 4231 (adopted August 4, 2014) states “Classified staff shall have opportunities to participate in staff development activities in order to improve job skills, retrain to meet changing conditions in the district, and/or enhance personal growth.” AR 4231 (adopted August 4, 2014) identifies the following potential staff development opportunities: • Orientation and support for new employees • Visits to other schools and school districts • Attendance at professional conferences or committee meetings • Classes and workshops offered by the district, county office of education, institutions of higher education, private organizations, or other appropriate agencies • Joint staff preparation time and staff meetings • Follow-up activities that help staff implement newly acquired skills 4. The 2022-23 staff training plan spreadsheet shows various organizations offered the workshops attended by staff members including the county office of education, California Association of School Business Officials (CASBO), and School Services of California. 5. Assessing procedures for core business office functions and establishing or modifying systematic procedures includes evaluating the skill levels of individual staff members for assigned duties. Interviews continue to indicate that staff members desire or need training and/or additional training in several areas, including those related to procurement and inventory practices and regulations, the new financial software system, payroll, ASB oversight, Excel, and accounting. During this review period, interviews indicated that the CBO often pulls staff out of scheduled trainings to work on other tasks. Recommendations for Recovery 1. A formal staff development plan should be developed for the Business Services Department targeted to specific district goals and/or objectives. The district should evaluate the skill levels of each staff member. The focus should be on content areas where deficiencies were previously identified during employee performance evaluations and with deficiencies noted in the annual audit reports or other regulatory agency reviews. The input of business office supervisors and managers should also be used to identify appropriate training and cross-training programs that meet the identified professional development needs of staff members. 2. Appropriate resources should be identified to fund the training included in the staff development plan. Financial Management 229 3. The business office staff should continue to attend routine trainings offered by the county office and other professional organizations and seek additional fiscal training and guidance to develop and enhance sound business practices and technical skills. 4. The district should continue its work to incorporate professional development activities into a formal staff development plan for each business office staff member and manager. These plans should include a calendar of training offerings and dates that each individual is scheduled to attend to fulfill professional development expectations. 5. Unless there is an emergency that cannot be addressed by another individual, staff should not be interrupted during scheduled training. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 230 Financial Management 3.2 Staff Professional Development Professional Standard The LEA develops and uses a professional development plan for the in-service training of school site/department staff by business staff on relevant business procedures and internal controls. The plan includes a process to seek input from the business office and the school sites/departments and is updated annually. Findings 1. The district has not established a formal staff development plan for the business office staff to provide training to school site/department staff. During the prior review period, the Business Services Department hosted a training for site/department staff. The training included topics such as budget, purchase requisitions, accounts payable, extra duty timesheets, personnel requisitions and attendance reports. An attendance roster was not provided to FCMAT, so it is unknown who attended the training. The business office was also planning to provide in-service training in February 2022, which reportedly would have included more detailed information about business-related functions; however, no evidence was provided during this review period to show that the training was conducted. Business office staff also indicated that 1-on-1 training is provided to site and department staff as requested and/or as needed for various business functions. 2. As discussed in Standard 2.1, office manager and administrative secretary meetings continue to be conducted by the HR Department where district departments, including Business Services, provide information and training regarding district forms, processes and procedures. Interviews with site and department staff indicated the meetings are generally well received. Interviews also indicated that the CBO, and often other business office staff members, attend the districtwide principals’ meetings monthly and provide information and training about various Business Services Department functions and procedures. 3. Interviews with school site/department administration and support staff indicated that some individuals need and/or desire initial or additional training in areas such as the new financial system, budget, account codes, ASB and the student information system. School site/department staff should receive routine guidance and training in all content areas related to business activities including, but not limited to, budget management, procurement, enrollment and attendance, and ASB, as applicable. A best practice is to ensure all staff members receive annual trainings to update or correct routine practices. Additionally, staff member turnover or movement within a district is not uncommon, and all staff members who are new to the district, site/department or position should receive training upon assuming the position. Financial Management 231 Recommendations for Recovery 1. A formal professional development plan should be established for the business office staff to provide school site/department staff with in-service training on relevant business procedures and internal controls. 2. The district should ensure that the staff development plan includes a process to seek input and identify the professional development needs of school site/department staff and is updated annually. 3. The district should ensure that all applicable school site/department staff members receive annual trainings to update or correct routine business practices, and all staff members who are new to the district, site/department or position should receive training upon assuming the position. It should also consider making attendance at these trainings mandatory for all applicable staff members and ensure that attendance rosters are completed for all trainings. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 232 Financial Management 4.2 Internal Audit Professional Standard Internal audit findings are reported on a timely basis to the audit committee, board and admin- istration, as appropriate. Management then takes timely action to follow up and resolve audit findings. Findings 1. The primary objective of an internal audit is to provide the district management with an independent assessment of monitoring systems, review procedures, authorization process- es, and organization risk and controls. Internal audits also provide an opportunity for the district to improve and mitigate overall risk, including the detection of fraud or misappro- priation of funds by employees in the normal course of business. The district has yet to implement a formalized internal audit program. It had previously assigned the function of internal audit to the director of fiscal services position, but that individual did not have the capacity to implement a formalized internal audit program due to limited time availability. At the time of FCMAT’s fieldwork for this review, the indi- vidual in this position was new, and had only served as the interim director for a couple of weeks; the position had been vacant since October 2022, and consequently no additional progress has been made. The county administrator should fully implement an internal audit program and an audit committee (as recommended in Standard 1.1). Internal audits should first be focused on those areas of weakness identified in the district’s annual independent audits to ensure organizational risk is minimized, and policies, procedures, laws, and regulations are fol- lowed. Internal audit reports or summaries should include sufficient quantifiable detail so that progress is measurable upon follow-up. Detailed recommendations should also be de- scribed. Internal audit findings should be resolved in a timely manner to the satisfaction of an audit committee. Additionally, procedures should be established to prevent any similar findings from occurring in the future. 2. Management is responsible for resolving any findings and recommendations from the district’s annual independent audit. The district does not have an audit finding board policy or administrative regulation that establishes the procedure to address audit findings in a timely manner. There is no formalized process that assigns responsibility for correct- ing the findings to specific employees. Upon receipt of the annual audit report, the district should do the following: • Identify the department and staff member assigned to address each spe- cific audit finding. Financial Management 233 • Document the details about when the audit finding was discussed with the affected department, a proposed audit finding resolution date and the actual date of audit finding resolution. • Document administrative verification that the corrective action for each audit finding has been implemented. A copy of the documented audit finding resolution should be provided to the district audit committee and the audit firm. Annual audit findings should be presented to the audit committee, and internal audit/ follow-up should be completed to ensure audit finding corrective action plans are imple- mented and resolved in a timely manner to the satisfaction of the audit committee. Addi- tionally, operational procedures should be reviewed and updated to prevent similar find- ings from occurring in the future. Recommendations for Recovery 1. The district should adopt board policies and administrative regulations to establish an internal audit function and ensure that internal audit practices are fully implemented. 2. The district should develop an audit finding board policy and/or administrative regulation and incorporate an audit finding resolution worksheet to establish procedures for resolu- tion. The procedures should clearly describe the process for conducting internal audits including the format for reporting findings and recommendations, and the process for resolving internal and external audit findings. The policy should require timely resolution, and “timely” should be clearly defined. 3. The district should establish an audit committee that is responsible for monitoring inter- nal and external audit findings. 4. Internal and external audit findings should be reported to an audit committee, which should then report to the county administrator/board. If circumstances merit such action, the county administrator should report possible irregularities that may warrant a fraud audit to LACOE for further investigation. 5. The district should ensure it has sufficient qualified staff in the Business Services Depart- ment who are trained and cross-trained to fully implement and expand internal audit practices to improve weaknesses in control activities identified in audit findings and this report. 234 Financial Management Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 1 July 2018 Rating: 1 July 2019 Rating: 1 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 2 July 2023 Rating: 1 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale Not Fully Financial Management 235 5.1 Budget Development Process Professional Standard The board focuses on expenditure standards and formulas that meet the goals and maintain the LEA’s financial solvency for the current and two subsequent fiscal years. The board avoids specific line-item focus, but directs staff to design an entire expenditure plan focusing on student and LEA needs. Findings 1. As discussed in Standard 2.3, a representative from the advisory board has been appointed to serve on the Budget Advisory Committee, and members’ attendance and participation at most board meetings has continued during this review period. Interviews indicated that board members are involved and ask questions at meetings and continue to learn about the budget and the district’s financial condition and that some board members also attended the California School Boards Association’s annual conference during this review period. 2. The online agenda for the March 9, 2022 regular board meeting included the approval of the 2021-22 second interim budget report and provided a PowerPoint presentation, the Standardized Account Code Structure (SACS) documents and a written narrative as attachments. The PowerPoint presentation contained an explanation of some key budget terminology and information such as the budget and financial reporting cycle, certification status, enrollment trends, a summary of budget changes from one reporting period to the next, cash flow projections for the current year, a summary of the unrestricted general fund budget and MYFP totals, and the updated Fiscal Stabilization Plan (FSP). The narrative report included information about many of the major assumptions used to develop the budget and MYFP; however, the assumptions shown in the narrative appear to be the same as those used in the 2021-22 first interim report rather than the most current information available at the time. The documents showed projected deficit spending in the unrestricted general fund of $4.8 million in 2022-23 and $6.0 million in 2023-24. The meeting minutes indicated that the CBO gave a presentation regarding the second interim report and that the advisory board provided comments regarding the item prior to its approval by the county administrator with a positive certification. 3. The online agenda for the June 29, 2022 regular board meeting included the adoption of the 2022-23 budget and provided a PowerPoint presentation, the SACS documents and a written narrative as attachments. The PowerPoint presentation contained an explanation of some key budget terminology and information such as the budget and financial reporting cycle; legal requirements; enrollment trends; major assumptions; a budget summary for the unrestricted, restricted and combined general fund; MYFP summaries for the unrestricted and combined general fund; the updated FSP; and cash flow projections for the current, budget and first subsequent years. The narrative report included information about many of the major assumptions used to develop the budget and MYFP. The documents showed projected deficit spending in the unrestricted general 236 Financial Management fund of $6.4 million in 2022-23, $500,000 in 2023-24 and $7.3 million in 2024-25. The meeting minutes indicated that the CBO gave a presentation on the budget and that the advisory board provided comments regarding the item prior to its approval by the county administrator. 4. The online agenda for the December 14, 2022 regular board meeting included the approval of the 2022-23 first interim budget report and provided a PowerPoint presentation and the SACS documents as attachments. The PowerPoint presentation contained an explanation of some key budget terminology and information such as the financial reporting cycle; certification status; enrollment trends; a summary of unrestricted, restricted and combined general fund budget totals; a summary of unrestricted general fund budget changes from one reporting period to the next; contributions to restricted resources; a summary of the unrestricted general fund MYFP totals; the updated FSP; and cash flow projections for the current year. A narrative report was not provided as an attachment to the board meeting agenda, and the PowerPoint document did not include the major assumptions used to develop the budget and MYFP. A narrative report, which appears to have been provided at the board meeting, was given to FCMAT. The narrative report included information about many of the major assumptions used to develop the budget and MYFP; however, some of the assumptions shown in the narrative appear to be the same as those used in the 2022-23 adopted budget rather than the most current information available at the time. The documents showed projected deficit spending in the unrestricted general fund of $4.2 million in 2022-23, $3.7 million in 2023-24 and $10.8 million in 2024-25. The meeting minutes indicated that the CBO gave a presentation on the first interim report and that the advisory board provided comments regarding the item prior to its approval by the county administrator with a positive certification. 5. The SACS report format is highly technical, complex and difficult to read, necessitating some guidance and explanation. Additionally, the SACS report alone does not demonstrate the link between the budget and the district’s standards, goals and student needs. As indicated above, a PowerPoint presentation and written narrative were also provided at each reporting period, and the CBO made presentations at each board meeting to help communicate financial information. The information provided in the online agenda backup materials at each reporting period should consistently include all the major assumptions used to develop the budget and multiyear projection and be based on the most current data available at the time. This will allow the advisory board, staff and public to understand how the educational goals are reflected in the budget. A properly prepared presentation can demonstrate the district’s progress towards fiscal solvency, isolate areas of concern, and focus on expenditure standards, formulas and student and district needs. 6. The county administrator sends a WEEKLY BOARD MEMO to the district’s board members. The documents provided to FCMAT show that the memos include updates provided by the Business Services Department about matters such as construction projects, the Citizens’ Bond Oversight Committee, and the Alternate Income Form. The memos also include updates from other departments about topics such as student enrollment and attendance, negotiations, special education, and IT. Financial Management 237 Recommendations for Recovery 1. The district should conduct, and the advisory board members should attend board study sessions/workshops to receive more detailed information on their role in developing the budget and its connection to student achievement. The advisory board members should also continue to attend outside budget workshops. 2. In addition to all the SACS forms, the district should consistently provide board members with a written narrative that includes comprehensive financial information in an understandable format and the complete set of major assumptions (based on the most current information available at the time) used to develop the budget, interim reports and multiyear financial projections. This information should be provided in the online agenda backup materials. 3. The district should continue to revise its FSP as needed and implement the plan to ensure fiscal solvency, include the advisory board and community throughout the process, and ensure the plan is approved by the county administrator. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 3 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 238 Financial Management 5.2 Budget Development Process Professional Standard The budget development process includes input from staff, administrators, board and community as well as a budget advisory committee. Findings 1. One of the most powerful ways to gain input regarding budgetary and instructional issues from those affected, including the advisory board, staff, community and employee associations, is the LCAP, a comprehensive district plan that must be aligned with the budget. Per EC 52060, the district’s LCAP (as well as the LCAP for each district-operated charter school) is to include a description of its annual goals for pupils to be achieved for each of the state priorities and for any additional local priorities. The LCAP should provide district staff with the information necessary to develop a budget and to accomplish the actions necessary to achieve the district’s goals. The following depicts how the plan was handled at the district during this review period: • A public hearing for the proposed 2022-23 LCAP was held at a regular board meeting on June 22, 2022. The minutes indicated that one individual provided public comments during the hearing. Prior to the public hearing, the chief academic officer presented the LCAP, and the minutes indicated the board provided comments regarding the presentation and that all five of the advisory board members were at the meeting. • After a presentation by the chief academic officer, the county administrator adopted the 2022-23 LCAP at the June 29, 2022 regular board meeting, prior to adoption of the 2022-23 budget. The minutes indicated the advisory board provided comments regarding the presentation and that all five of the advisory board members were at the meeting. Standard 6.1 of this report provides additional information on the public hearing and adoption processes for the LCAP and budget. 2. EC 52060 states the following: The governing board of a school district shall consult with teachers, principals, administrators, other school personnel, local bargaining units of the school district, parents, and pupils in developing a local control and accountability plan. Such meetings are opportunities to involve the board, community, employee associations, and other affected parties to satisfy the required LCAP engagement, seek input for budget development, and build transparency. Financial Management 239 The LCAP documents provided at the June 22 and 29, 2022 board meetings included the survey results from students, parents, and staff; indicated that numerous groups were engaged in the LCAP process; stated that one LCAP Committee meeting was conducted since February 2022 and that committee meetings were open to the community. The district’s Parent Engagement Meeting Calendar 2022-2023 showed that several meetings were scheduled with various groups from September 2022 through January 2023. 3. The district continues to have a Budget Advisory Committee, but district documents show no meetings were conducted during this review period. The 2022 Budget Advisory Committee member list indicated that committee membership included the county administrator, two advisory board members, a district/school administrator, bargaining unit representatives, a parent, students, and facilitators from the business office. 4. Interviews indicated that the monthly online meetings with each principal to discuss their budgets and staffing have continued during this review period, and a monthly budget meeting schedule was developed for department leaders, but they were not involved in development of their respective 2022-23 budgets. The meetings include staff from the Business Services and Educational Services departments. Recommendations for Recovery 1. The district should continue to actively seek input from the advisory board members, parents, students, community, staff and bargaining units during the budget development and LCAP process. 2. The district should continue to ensure that the LCAP guides budget development and is incorporated in the budgeting process. 3. The district should routinely schedule and conduct Budget Advisory Committee meetings. 4. The district should conduct timely meetings with all department managers and continue to conduct timely meetings with site administrators regarding budget development. 240 Financial Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 241 5.3 Budget Development Process Professional Standard The LEA has clear policies and processes to analyze resources and allocations to ensure that they align with strategic planning objectives and that the budget reflects the LEA’s priorities. The budget office has a technical process to build the preliminary budget that includes revenue and expenditure projections, the identification of carryovers and accruals, and any plans for expenditure reductions. The LEA utilizes formulas for allocating funds to school sites and departments. This may include staffing ratios, supply allocations, etc. Standardized budget worksheets are used to communicate budget requests, budget allocations, formulas applied and guidelines. A budget calendar contains statutory due dates and major budget development milestones. Findings 1. BP 3000-Concepts and Roles (adopted August 4, 2014), states the following regarding budget development: In the development of a district budget, the Board and the Superintendent or designee shall establish a calendar that reflects the full budget cycle and a process that satisfies the requirements of law, including opportunities for public input. The Superintendent or designee shall provide fiscal data and prepare a proposed budget document within the budget priorities and parameters set by the Board. The Board shall adopt a budget that is aligned with the district’s vision and goals and enables the district to meet its fiscal obligations. BP and AR 3100-Budget, were adopted on February 20, 2019. These documents are specific to budget development and adoption, outline the budgetary responsibilities of the board and provide staff with specific direction for these processes. 2. As discussed in Standard 5.2, the LCAP lists the district’s goals and actions to achieve those goals; therefore, the LCAP should be an integral component of the budget. The district adopted its 2022-23 LCAP at the June 29, 2022 board meeting; the document included the LCFF Budget Overview for Parents. The agenda backup materials included a PowerPoint presentation with information regarding projected revenue and budgeted expenditures; the expenditure chart states that “It shows how much of the total is tied to planned actions and services in the LCAP.” The SACS criteria and standards forms for the 2022-23 adopted budget indicated that the district’s budget includes the expenditures necessary to implement the LCAP, and the September 14, 2022 oversight letter indicated that the county office approved the district’s LCAP. However, the 2022-23 budget and first interim assumptions narrative documents and/or PowerPoint presentations do not include discussion of the district’s LCAP, so readers cannot easily discern the extent of its inclusion in the budget at each reporting period. 242 Financial Management 3. The FSP is a multiyear strategic blueprint critical to the district’s ability to regain fiscal solvency. The 2022-23 adopted budget narrative included the updated FSP, and the document was provided with the June 29, 2022 board meeting materials. The FSP was also updated at the 2022-23 first interim reporting period and was included with the December 14, 2022 board meeting materials. The FSP projects a remaining unrestricted general fund deficit of $4.8 million in 2024-25 after the planned actions are implemented. 4. During the prior review period, the county administrator approved the 2021-22 Budget Development Calendar at the February 17, 2021 board meeting. The calendar included due dates for completing numerous actions related to budget development, but it did not include the department and/or position responsible for completing each task. The calendar did not include some of the key tasks for budget development such as the date for completion of staffing projections prior to March 15, the date that site administrators and department managers are to receive budget forms/worksheets, and the date that the completed forms/worksheets are to be submitted to the business office. A 2022-23 budget development calendar was not provided to FCMAT, and at the time of fieldwork, the budget development calendar for 2023-24 had not yet been approved. 5. During the prior review period, the Business Services Department revised the Budget Development Process for School Sites and Department manual that provided some information to administrators about 2021-22 budget development. It included information regarding projected school site enrollment; employee position types; and preliminary general fund, supplemental and concentration grant, and Title I site allocations. The business office also provided school sites with budget development worksheets, which included instructions for completion, site allocations by resource, actual expenditures to date, a position control site staff list and a chart of accounts. Documents indicated that the budget development manual and budget allocations were reviewed with principals and that the budget worksheets were to be completed and returned to the business office. Documents provided to FCMAT for 2021-22 budget development also included various spreadsheets with projections for enrollment and ADA, LCFF funding, and SELPA allocations. No information was provided regarding staffing formulas and projections, or forms/worksheets used to develop department budgets. 6. At the time of FCMAT’s fieldwork for the current review period, the former CBO and senior executive director of fiscal services, who were the primary business office staff members responsible for 2022-23 budget development, were no longer with the district. A 2022-23 budget development manual was not provided to FCMAT; however, school site budget development worksheets were provided, and they mentioned a 2022-23 School Site Budget Development Manual. The instructions tab of the worksheets referred to the 2021-22 budget development process, but the allocation tabs indicated the budget information was for 2022-23; the worksheets also included a staff list and chart of accounts. Documents provided to FCMAT for 2022-23 budget development also included various spreadsheets with projections for enrollment and ADA and SELPA allocations. No documentation was provided about staffing formulas, the formulas used to determine site allocations, or forms/worksheets used to develop department budgets. Financial Management 243 7. In some previous review periods, the district experienced significant year-over-year carryovers of Title I funds, which required a wavier to be filed for excess carryover beyond the 15% allowance. Providing carryover funds late in the school year, either at the districtwide or school site level, puts the district at risk of exceeding the maximum carryover amount allowed by restricted funding sources. During the current review period, interviews were inconsistent about when carryover funds are included in the budget. Recommendations for Recovery 1. The district should include a brief discussion and/or summary of the LCAP expenditures in the budget narrative documents. 2. The district should continue to revise its FSP as needed and implement the plan to ensure fiscal solvency. 3. The district should ensure that site administrators and department managers are an integral part of budget development and continue to provide them with training on budget development and monitoring. 4. The district should continue to use standardized budget worksheets for school sites and develop and implement standardized budget worksheets to communicate department budget allocations; budget worksheets should include consistent information about the budget development year. Each site/department budget manager should be required to complete the worksheets indicating the account codes where funds are to be budgeted and submit the completed forms to the business office. 5. The district should ensure that a budget calendar is developed and implemented each year, and that it includes deadlines for all budget tasks and the department and/or position assigned to complete each task. The calendar should be disseminated to all who are responsible for such tasks. 6. The district should include carryover in site and/or districtwide budgets before the first interim reporting period, but only after it has finished closing its books for the previous fiscal year. Site and department administrators should be notified when carryover is provided and the amount for each resource. 7. The district should ensure that budgets are monitored throughout the year and that restricted resources do not exceed allowable carryover balances since this may necessitate the return of funds to the grantor. 244 Financial Management Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 3 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 245 6.1 Budget Adoption, Reporting, and Audits Legal Standard The LEA adopts its annual budget within the statutory timelines established by EC 42103, which requires that on or before July 1, the board shall hold a public hearing on the budget to be adopt- ed for the subsequent fiscal year. Not later than five days after that adoption or by July 1, which- ever occurs first, the board shall file that budget with the county superintendent of schools. (EC 42127(a)) Findings 1. EC 42127(a)(1) and 52062 require school districts to hold two separate public board meetings at least one day apart. The first meeting is for the LCAP and budget public hearings, and the second is for the LCAP and budget adoption. The LCAP adoption item must precede the budget adoption item (EC 42127(a)(2)(A)). The public hearings require 72 hours public notice, and both the LCAP and the budget must be adopted on or before July 1 each year. 2. The district made presentations regarding the proposed 2022-23 LCAP and the proposed 2022-23 budget at its June 22, 2022 board meeting. Later in the meeting, the district conducted public hearings seeking input on the proposed 2022-23 LCAP and the proposed 2022-23 budget. The minutes indicate that one individual provided public comment for the public hearings. 3. Per EC 52062(b)(2), the meeting for the public hearings and the meeting for the adoption of these documents are to take place at least one day apart to ensure there is an opportunity to incorporate revisions, if needed, in consideration of the input discussed during the public hearings. The June 29, 2022 meeting minutes indicate that the 2022-23 LCAP and the 2022-23 budget were adopted at least one day after the public hearings. 4. The district prepared its 2022-23 proposed budget and LCAP, and Form CB of the budget documents indicated these documents were made available for public inspection at least three days prior to the board meeting scheduled for a public hearing as required by EC 42127(a)(1) and 52062(b)(1). 5. The county office’s review letter dated September 14, 2022 approved the district’s 2022-23 LCAP and budget. The letter noted that the district projected deficit spending of approximately $6.35 million in 2022-23, a deficit of $500,000 in 2023-24, and a deficit of $7.29 million in 2024-25. The district was required to address deficit spending in the update to its FSP and submit it with the 2022-23 first interim report. 6. County office staff indicated that the district continues to meet the budget submission timelines as required by EC 42127(a). 246 Financial Management Recommendations for Recovery 1. The district should continue to hold public hearings for its LCAP and proposed budget at least one day prior to the board meeting to adopt the LCAP and budget, on or before July 1 of each year, in accordance with EC 52062, and ensure action on the LCAP precedes action on the proposed budget in accordance with EC 42127(a)(2)(A). 2. The district should continue to file its adopted budget with the county superintendent of schools within five days of its adoption or by July 1, whichever occurs first. Standard Fully Implemented July 2013 Rating: 7 July 2014 Rating: 8 July 2015 Rating: 7 July 2016 Rating: 7 July 2017 Rating: 8 July 2018 Rating: 9 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 247 6.2 Budget Adoption, Reporting, and Audits Legal Standard Revisions to expenditures based on the state budget are considered and adopted by the govern- ing board. Not later than 45 days after the governor signs the annual Budget Act, the LEA shall make available for public review any revisions in revenues and expenditures that it has made to its budget to reflect funding available by that Budget Act. (EC 42127(h)) Finding 1. Governor Gavin Newsom signed the 2022-23 State Budget Act on June 27, 2022; therefore, the district was required to make public any budget revisions made as a result of the enacted state budget by August 11, 2022. The district’s adopted budget was based on the May revision, which differed significantly from the enacted state budget. The CBO presented a report on the budget changes at the regular board meeting on August 10, 2022; however, revisions to the district’s 2022-23 budget were not presented for approval by the county administrator/board. Recommendations for Recovery 1. The district should continue to follow the requirements of EC 42127(h) within 45 days of the governor signing the annual Budget Act. 2. The district should present any budget revisions to the county administrator/board for approval. 248 Financial Management Standard Fully Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 5 July 2016 Rating: 7 July 2017 Rating: 8 July 2018 Rating: 9 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 249 6.3 Budget Adoption, Reporting, and Audits Legal Standard The LEA completes and files its interim budget reports within the statutory deadlines established by EC 42130, et. seq. All reports are in a format or on forms prescribed by the superintendent of public instruction and are based on standards and criteria for fiscal stability. Findings 1. During this review period the district filed the following interim reports: • 2021-22 second interim report, approved at a regular board meeting on March 9, 2022 • 2022-23 first interim report, approved at a regular board meeting on December 14, 2022 Financial reports for each interim reporting period submitted to the county office during this review period were in the SACS format; and although not all conditions in the criteria and standards section were met, they included assessments of the district’s fiscal stability for each of the criteria and standards measured by data in the SACS supplemental reports. 2. EC 42130 requires that the second interim report describe the district’s financial and bud- get status for the period ending January 31 and be approved by the district’s board within 45 days, or by March 17, 2022. Minutes of the district’s March 9, 2022 board meeting indicated approval of the 2021-22 second interim report in compliance with the statutory deadline. 3. Because the district filed a positive certification for its 2021-22 second interim report, it was not required to submit an end of year financial statement, projecting its fund and cash balances through June 30, 2022, for the period ending April 30, 2022. This is commonly referred to as a third interim report. 4. EC 42130 requires that the first interim report describe the district’s financial and budget status for the period ending October 31, and be approved by the district’s board within 45 days, or by December 15, 2022. Minutes of the district’s December 14, 2022 board meet- ing indicated approval of the 2022-23 first interim report in compliance with the statutory deadline. A consultant prepared the 2022-23 first interim report on the district’s behalf. The district’s 2022-23 first interim report shows a projected unrestricted general fund defi- cit of $4.16 million in 2022-23, a deficit of $3.72 million in 2023-24 and a deficit of $10.82 million in 2024-25. The district’s FSP submitted with its first interim report includes ongoing expenditure reductions and revenue increases of $3.08 million in 2022-23, and additional expenditure reductions totaling $5.83 million in 2023-24 and $10.05 million in 2024-25. The county office’s review letter stated that only the 2022-23 cost savings and expenditure reductions were reflected in the first interim MYFP. The district needs to fol- low through with expenditure reductions and/or revenue enhancements to eliminate the operating deficit and maintain the required reserve for economic uncertainties. 250 Financial Management 5. Inquiries with county office staff confirmed that the district submitted interim reports within the appropriate timelines. The county office’s review letter for the district’s 2021- 22 second interim report was dated April 28, 2022, and the review letter for the 2022-23 first interim budget report was dated February 1, 2023. The county office’s 2022-23 first interim review letter stated that the district should be able to meet its financial obligations for the current and subsequent two fiscal years and concurred with the district’s positive certification. The county office expressed concerns about the projected trend of deficit spending and its impact on the district’s ability to maintain the required reserve in future years. The letter noted that the unrestricted general fund balance is projected to decrease from a beginning balance of $31.8 million in 2022-23 to an ending balance of $13.1 mil- lion in 2024-25, and that it must continue to implement the cost savings and expenditure reductions identified in its FSP to sustain its fiscal stability. Recommendations for Recovery 1. The district should continue to ensure that all interim reports comply with the conditions and timelines established in EC 42130 et. seq. 2. The district should ensure that the consultants it uses train district staff to build internal capacity. 3. The district should continue to ensure that all budget reports are approved by the county administrator/board and filed with the county office on time and include a plan to meet all financial criteria and standards for fiscal stability. Standard Fully Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 5 July 2016 Rating: 5 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 8 July 2022 Rating: 9 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 251 7.2 Budget Monitoring Professional Standard The LEA implements budget monitoring controls, such as periodic budget reports, to alert de- partment and site managers of the potential for overexpenditure of budgeted amounts. Revenue and expenditures are forecast and verified monthly. The LEA ensures that appropriate expendi- tures are charged against programs within the spending limitations authorized by the board. Findings 1. During the 2021-22 fiscal year, the district started its transition to LACOE’s Business Enhancement System Transformation (BEST) Advantage System, which replaced LACOE’s PeopleSoft financial system. The BEST Advantage System provides better integration between purchasing, budget and accounting and gives end-users the ability to have on-demand data and access to real-time reports regarding their accounts, including requisitions, purchase orders, contracts and payments. According to LACOE, the BEST budget module was live as of January 31, 2022, requiring the district to build its 2022-23 adopted budget in the new financial system prior to July 1, 2022. The financial module was live in May 2022 for requisitions and purchase orders and in July 2022 for general ledger, accounts payable, accounts receivable, inventory and asset management modules. Interviews indicated that district staff, including business office personnel, school site personnel and various department personnel all received training on the BEST Advantage System. According to LACOE’s website, the county office offered training via instructor- led webinars as well as self-guided e-learning courses. 2. Prior to the implementation of the BEST financial system, the district implemented FCMAT’s recommendation and was using the budget reports available from the PeopleSoft financial system through the Reports and Data (RAD) portal. Interviews with business office staff indicated these budget reports were sent to individual school sites and departments monthly and/or on request. Some departments and site staff had been trained to access budget information directly through PeopleSoft and therefore did not have to rely on the Business Services Department to receive the reports. However, interviews indicated that since the implementation of BEST, business office staff has resumed producing monthly budget reports for each school site and department. The BEST system is completely web-based and site/department users require authorization from the district office for access to the various modules to view their budget reports. In addition, new users are required to complete training for the requested application before access is granted. At the time of FCMAT interviews, not all sites/departments had access to their budget reports; therefore, business services staff is tasked with creating monthly reports for each site/department. Once these reports are created, sites have access to them through a shared Google drive or they are sent via email. 3. On December 14, 2022, the district approved an agreement with a consultant to automate the creation of monthly budget snapshot reports from the BEST system financial reports 252 Financial Management to allow business office staff to upload the snapshot reports to the Google drive monthly for site/department access. The district is creating customized budget reports instead of training site and department staff to use the reports that are available within the financial system. With appropriate access to the financial module within the BEST system, site/ department staff have access to current budget information including expenditures, encumbrances, and remaining balances. 4. Various business office staff meet with site/department personnel to review their budget reports, offer assistance with budget issues and provide training. Meetings include staff from the Educational Services Department to ensure sites use categorical funds correctly. FCMAT’s review of some categorical program budgets found large remaining balances in Title I and Elementary and Secondary School Emergency Relief Fund (ESSER) II & III programs as of January 2023, which represents approximately 50% of the fiscal year. For example, seven school sites and one department had unspent funds equal to 70% or more of their Title I allocation, and six school sites and 11 departments had unspent funds of over 75% of their ESSER II & III allocation. Although the ESSER II funds are not required to be fully spent until September 30, 2023 and ESSER III funds must be spent by September 30, 2024, funds that are not spent in a timely manner or not according to the district’s expenditure plan may need to be returned to the state. While some unused allocations were in the site’s supplies and services accounts, some staffing allocations had 100% remaining as unspent. Typically, the remaining balances in salary accounts reflect the remaining months in the fiscal year (e.g., if 50% of the fiscal year is left, the remaining balances in salary accounts should be approximately 50%). The BEST budget reports include a column that shows the percentage of funds remaining in each account line, making it easy for sites and departments to know which accounts need to be spent down. Communication with school sites is critical to keep the site principals and clerical staff informed of their categorical programs and discretionary allocations and to hold the sites accountable for monitoring their budgets. 5. During this review period, the district used both PeopleSoft and BEST financial systems for centralized budgeting and purchase requisition processing. Purchase requisitions follow an established process starting at the department or site level for authorization, followed by approvals with the cabinet-level administrator and/or executive director of state and federal programs, if necessary, to ensure program compliance with state and federal grants. Additionally, if sites or departments purchase technology equipment, the purchase requisition is routed to the executive director of IT for approval. The business services position control/budget analyst reviews purchase requisitions under $10,000 for budget availability before the requisition is forwarded to purchasing for further processing. Although a hard stop is preferable for processing purchase requisitions, the district uses a soft stop, which allows business office staff to override warnings when the account line has insufficient funds. Budget availability is determined for the overall site or department budget, not at the object code level; therefore, some object codes can have large negative balances and others positive balances. 6. The district uses a Budget Transfer Request Form that is initiated through the Informed K12 system. According to the budget transfer procedures, this form was created to address issues with purchase requisitions that would otherwise not have been processed Financial Management 253 or would have been delayed due to insufficient funds. The form is initiated by sites and departments, followed by approvals of the cabinet-level administrator and/or executive director of state and federal programs. Interviews indicated, however, that the business office does not enter each budget transfer request as it is submitted but instead processes large budget transfers at interim reporting periods unless a significant or major change is made to a specific program. The district did not provide supporting documentation to FCMAT for budget transfers entered during this review period. FCMAT’s review of the district’s budget report found that since the business office does not process the budget transfer requests regularly, various account lines still had negative balances. FCMAT continues to recommend that the district implement the online processing feature that stops users from encumbering a purchase requisition if sufficient funds are not available within a budget account code. Implementing this feature would provide adequate controls, ensure funds were not overspent, and save staff time that is devoted to constant review of budget availability. In addition, sites will know how much funding is available at any given time. While this involves training for site and department personnel, the overall benefit of the process will be to provide up-to-date information for managers to monitor budget and availability of funds and prevent duplication of work by the sites/departments that maintain Excel spreadsheets to track their budgets. 7. In the PeopleSoft financial system, purchase requisitions do not post to the encumbrance ledger, reducing the remaining budget balance, until the purchase order has been approved for processing at the district office level. As reported in several previous FCMAT reviews, the time lapse between initiation of a purchase requisition and district level review and processing can take several days. Therefore, depending on how long it takes to review budget availability and generate purchase orders, the inability to immediately encumber purchase requisitions can cause budgets to be overspent. The BEST financial system posts a preencumbrance as soon as a purchase requisition has been created and reduces the available budget in real time. On the budget inquiry page, the BEST system displays columns that reflect the current budget, encumbrances, actual expenditures, and unobligated amounts. When a user selects a specific account line, a preview window opens that displays amounts for preencumbrances, but those amounts are already deducted from the unobligated amount column, which reflects the available amount for that specific account line. 8. FCMAT continues to recommend that business office staff be evaluated to ensure staff have the necessary skills and ongoing training to perform essential functions. The district has implemented best practices for some critical functions that include basic budgeting practices, but has still not implemented proper budget monitoring or proper alignment of budget to actual expenditures. The result continues to reflect an unrealistic budget that has millions of dollars of overstatements and understatements in major object codes and poor internal control features at the site and district level. 254 Financial Management 9. FCMAT’s review of the district’s 2021-22 unaudited actuals found that the district had a net increase of $3.2 million in the unrestricted general fund balance and an increase of $12.3 million in the restricted general fund balance. The increase to the unrestricted fund balance was approximately $4.7 million less than what was estimated on the district’s estimated actuals report approved in June 2022. The table below shows the salaries and benefits for each of the various financial reports as they compare to the final unaudited actuals. This data shows that the district’s salaries and benefits were within 1.0% for unrestricted expenditures but were overstated by more than 17.9% for restricted expenditures at first interim as compared to the unaudited actuals. Those variances fluctuated throughout the year as actual expenditure information became known. The district’s estimated actuals, which were submitted with its 2022-23 adopted budget, were only slightly overstated for unrestricted expenditures but were overstated by 5.2% for restricted expenditures. It appears that the work being done on the unrestricted programs for employees’ salaries and benefits should be completed with the same thoroughness for the restricted programs at each of the interim and estimated actuals financial reporting periods. Fiscal Year 2021-2022 Reporting Adopted Budget First Interim Second Interim Estimated Actuals Unaudited Actuals Period EXPENDITURES: Unrestricted Restricted Unrestricted Restricted Unrestricted Restricted Unrestricted Restricted Unrestricted Restricted Certificated 24,677,399 20,369,929 28,987,085 15,483,666 30,588,442 14,787,349 28,562,280 13,695,722 29,291,072 12,927,050 Salaries Classified 8,869,062 12,333,950 7,492,878 14,260,036 7,132,003 13,494,601 8,284,752 9,201,382 7,781,782 8,857,929 Salaries Employee 17,303,447 14,243,098 17,051,263 13,043,852 16,793,906 12,378,725 17,315,738 14,168,832 16,093,969 13,337,610 Benefits TOTAL $50,849,907 $46,946,977 $53,531,226 $42,787,554 $54,514,351 $40,660,675 $54,162,770 $37,065,936 $53,166,823 $35,122,589 EXPENDITURES: Variances: Vs. Unaudited 4.56% -25.19% -0.68% -17.91% -2.47% -13.62% -1.84% -5.24% Actual Upon review of the district’s 2021-22 unaudited actuals, FCMAT found that while the district had made some progress, it had not fully reconciled and cleared its balance sheet accounts. This was one of the same issues raised in FCMAT’s review of the district’s prior two years’ unaudited actuals. Unreconciled balance sheet and general ledger accounts, especially over multiple years, are an internal control weakness that can adversely affect the district’s operating budget, cash and net position. District leadership should make reconciliation a priority in the current year. Interviews conducted in the last review period indicated that staff members were researching these issues and hoped to have the accounts cleared for the 2021-22 unaudited actuals. In the current review period, the district hired a consultant to reconcile the balance sheet accounts. The consultant recommended and the district posted a restatement to the general fund in the 2022-23 fiscal year reducing the fund balance by $929,895. As further discussed in Standard 8.2 and 10.4, the district does not routinely reconcile and clear its balance sheet accounts and fund 76, which can lead to material misstatements of its fund balance. The consultant proposed a restatement to fund 76 totaling $793,585.56, which the district posted in the 2022-23 fiscal year. Financial Management 255 10. The district continues to make extremely large unrestricted general fund contributions to support special education program costs including transportation. According to the 2022-23 first interim report, the contribution to special education is projected to be $29.0 million, or 73.71% of the total special education expenditures. The 2021-22 unaudited actuals SEMA report shows a contribution of $23.0 million, or 67.80% of the total special education expenditures. 11. Interviews with staff confirmed that budgeted expenditures and vendor invoice tracking for special education costs, including nonpublic schools/agencies (NPS/NPA), lack thorough management review. FCMAT has continued to identify the need for internal controls and procedures to properly project expenditures and to implement special education cost containment measures, and the need for additional oversight for all special education program expenditures. (Additional information is provided in Standard 20.1.) Recommendations for Recovery 1. The district should continue to use the controls available in the new purchasing system so that funds are encumbered at the requisition level, and it should not override the controls allowing the purchase to proceed without sufficient funds. 2. The district should continue the implementation of the site/department budget transfer pro- cess and initiate a hard-stop control at the account code level in the purchasing process. 3. Budget transfers should have sufficient supporting documentation, and the site or department should initiate them before submitting the purchase requisition for business office approval. The district should process budget transfers timely rather than only at interim reporting periods to prevent overspending budget allocations. 4. The district should continue to send budget reports to site and department administrators at least monthly and encourage administrators and managers to use the online capability in the financial system to review their site and/or department budgets. 5. The district should ensure that the budget is routinely monitored and properly aligned with projected revenues and expenditures. 6. The district should review and reconcile balance sheet accounts and fund 76 monthly. 7. The district should evaluate business office staff to ensure staff have the necessary skills, are properly trained and held accountable to perform essential functions. 8. The Business Services Department and special education management should review en- cumbrances for NPA/NPS services and other special education expenditures at least quar- terly and adjust the encumbrances as needed. 256 Financial Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 1 July 2017 Rating: 0 July 2018 Rating: 1 July 2019 Rating: 1 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 257 7.3 Budget Monitoring Professional Standard The LEA uses an effective position control system that tracks personnel allocations and expendi- tures. The position control system establishes checks and balances between personnel decisions and budgeted appropriations. Findings 1. Prior to the start of the 2022-23 fiscal year, the district used PeopleSoft as its accounting and financial reporting software provided by LACOE. The district started its transition to LACOE’s BEST financial system in January 2022, with full implementation of the budget and finance modules on July 1, 2022. The district has not yet implemented the BEST system’s Human Capital Management module, a human resource and payroll system for position control, personnel management, and payroll accounting. The district still uses the Human Resource System (HRS), a personnel, payroll and retirement system that is separate from, but integrated with PeopleSoft and now integrated with BEST. The BEST Advantage System has replaced the PeopleSoft financial system, and eventually HRS, with an integrated budgeting, financial, human resources, and payroll system. The position control module is located within HRS as a separate database. The district fully implemented the position control module several years ago. The position control system provides a link between HRS, payroll and budget; therefore, effective procedures and management oversight are essential elements to ensure that information is updated and revised regularly, and that defined roles between the HR and Business Services departments are established to ensure separation of duties and continual maintenance of changes in personnel and positions. Used properly, position control is a valuable tool. The district has continued to experience turnover in critical positions within the Business Services and HR departments, both of which have a critical role in the main- tenance of the position control process (software). 2. As recommended in previous reviews, each position should ideally be stored in the database using a unique position control number. When the district implemented position control, groups of like-kind employees with similar funding sources at each site were established using one position control number. Using the position control system this way prevents those responsible for position control and human resource management from knowing how many vacancies exist within each position control number, how many employees hold unique credentials and certifications, and other necessary data for budgeting, hiring and decision-making. In addition, having a unique position control number for each position is especially useful as the district downsizes staffing due to declining enrollment. 3. Last year, the business office staff prepared a reconciliation of the 2021-22 first interim budget compared with a detailed position control report including actual payroll to date and projections for the remaining months. Including the actual to date information is essential as it will help identify discrepancies that both HR and Business Services can address. The 2022-23 first interim budget position control report did not include the 258 Financial Management actual-to-date payroll information, which would be helpful in determining if the district has over- or underbudgeted positions. FCMAT’s review of the position control report found some monthly salary amounts did not align with actual payroll, nor did the report include reductions for the periods in which positions were vacant. With the turnover in staff, it seems that the district is mainly using the report to ensure all positions are accounted for but is no longer integrating it with actual payroll information for budgetary accuracy. Interviews indicated that staff reduced budget allocations for all vacant positions by 50% in the 2022-23 first interim financial report rather than reducing the allocations to zero for positions that would not be filled in the current year. Interviews indicated that the 2022-23 first interim budget included costs for vacant positions, although the district had hired consultants to perform the work, which inflated the personnel budget. Additionally, the funding source for at least two employees, each working in two different departments, is shown on the position control report as allocated 100% to one department instead of being allocated properly between the two departments. 4. Interviews indicated that district staff recognizes it cannot monitor the budget properly if the position control database is not accurate. The district has continued to work on implementing processes and procedures to ensure both Business Services and HR departments’ staff have been trained correctly on position control. Interviews indicated that the departments have continued to meet every two weeks to review and reconcile positions within position control, but the actual payroll and position control are still not reconciled. 5. The position control system should include amounts for items such as overtime, extra-duty pay, stipends, substitutes, vacation payouts and estimated column movements; all payroll related costs should be included in the system because it ultimately populates the district’s budget. The district uses multiple position control numbers for these activities instead of lump sums. To reduce redundancy, the district should combine like-kind items such as overtime that are included in several different account codes. This will reduce the volume of work for HR and Business Services department staff to manage these additional compensations. Additionally, the way that the district accounts for overtime, extra-duty pay, stipends and sub- stitutes show these types of positions as vacant in the position control system. This method is not conducive to determining actual vacancies. The district should be able to run a report from the position control system at any given time and produce a list of all vacant positions, which should ultimately match job openings posted by the HR Department. 6. While a district typically has vacancies throughout the fiscal year, forecasting the full costs of these positions is not a best practice because they generate payroll savings during the time of vacancy. Savings for unfilled positions should be recognized to provide a more realistic budget projection and financial position. 7. The district had a 13-step process for personnel requisitions. Using Informed K12, a digital workflow processing software, requests move electronically from the initiator through the approval process and ultimately are used to update position control. Leaders of the HR and Business Services departments recognized that this was a cumbersome Financial Management 259 process that needed to be reduced while maintaining proper checks and balances and has since implemented a revised nine-step process that has reduced the approval processing time. FCMAT’s review of the Informed K12 workflow chart shows that it includes positions in an approver role that are no longer occupied. It was also unclear to FCMAT where in the nine-step process county administrator/board approval occurs. The district should ensure that the workflow chart reflects the current process and should review and update its approvers when staff changes occur. Interviews indicated that the HR Department is still hiring personnel before the process has completed. 8. Interviews with business office staff indicated that the business office provides the site principals with staffing reports monthly. However, some school site principals indicated they receive the staffing reports only two to three times a year. Each administrator is to verify his or her list and report any errors, then the business office staff works with HR to process any necessary revisions in the position control system. During interviews, there seemed to be some confusion about which database is used to track this data. The HR Department uses Airtable to manage employee data and the Business Services Department uses the HRS system, and it was unclear which report is provided to the sites. The sites should be receiving the staff reports from the position control system that are used for financial reporting so any errors can be corrected timely. Recommendations for Recovery 1. The district should provide unique position control numbers for each county administra- tor/board-authorized position. 2. The district should consider using lump-sum amounts for certain additional compensa- tion in the position control system instead of unique position control numbers. 3. To properly track vacant positions, the district should not account for additional compen- sation as vacancies in the position control system. 4. Defined roles between the HR and Business Services departments should continue to be established and implemented to ensure separation of duties and continual maintenance of changes in personnel and positions. 5. The district budget should include salary and benefit savings for positions that will not be filled in the current and/or future fiscal years to provide a more realistic financial position. When the county administrator/board eliminates positions, these should be immediately removed from position control projections. 6. The Business Services and HR departments should continue to review periodic reports in the position control system to ensure that additions and deletions have been completed and that total full-time equivalent positions, salaries and benefits fairly represent amounts populated in the budget less salary savings generated from open and vacant positions. 7. The district should compare the actual expenditures to date with the position control totals at each interim report period, and any major variances should be analyzed, and ap- propriate adjustments should be made to the budget. 260 Financial Management 8. The district should update and revise its personnel requisition workflow as approver changes are made and should ensure that the workflow chart reflects the current process. 9. All employees involved in the personnel requisition process should be provided with clear instructions on processing requisitions in a timely manner. 10. HR should not be allowed to hire until the personnel requisition has been fully approved. 11. The district should send position control reports to site and department managers rou- tinely (e.g., during budget development and at each interim reporting period) and ensure that data is reviewed and corrected as needed. The reports should include all the employ- ees at each respective site or department. 12. The district should ensure that the position control reports sent to sites and departments are generated from the database that is used for financial reporting. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 261 8.1 Accounting Professional Standard The LEA forecasts its cash receipts and disbursements and verifies those projections monthly to adequately manage its cash. The LEA reconciles its cash to bank statements and reports from the county treasurer monthly. Findings 1. The 2021-22 enacted state budget provided a compounded COLA of 5.07% on LCFF base grants and increased the concentration grant from 50% to 65%. In addition, per the provisions of SB 98 and SB 820, the district’s 2021-22 LCFF revenues were based on its 2019-20 ADA plus the 2019-20 ADA of two district-sponsored charter schools, which closed at the end of 2019-20.. The 2022-23 enacted state budget included a COLA of 6.56% plus 6.70% in additional funding for LCFF. AB 181 included some ADA loss mitigation measures including an ongoing change that allows districts to use the greater of current year ADA, prior year ADA, or the average of the three most recent prior years’ ADA to calculate LCFF funding. Another provision of AB 181 provided one-time ADA relief that allowed LEAs to use their 2019-20 attendance rate in 2021-22 if the 2019-20 rate was higher and certain conditions were met. These provisions had a positive effect on the district’s LCFF revenues and cash balances. However, the district’s multiyear projections show continued deficit spending and an erosion of the unrestricted fund balance. The district must work to eliminate the structural deficit in its unrestricted general fund and maintain a positive cash position. 2. The district prepared cash flow projections at budget adoption and interim reporting periods that balance to the budget. The district’s 2021-22 second interim report included cash flow projections for both the 2021-22 and 2022-23 fiscal years. The district’s 2022-23 adopted budget report included cash flow projections for the 2021-22, 2022-23, and 2023-24 fiscal years. The district’s 2022-23 first interim report included cash flow projections for both the 2022-23 and 2023-24 fiscal years. Most months, the district updated its cash flow projections for actual activity and the CBO gave a cash flow presentation at board meetings. The April and May 2022 board agendas and minutes indicated that the CBO gave a cash flow presentation, but it was not included as an attachment to the agenda. 3. The district’s 2021-22 cash flow projection submitted with its 2021-22 second interim report appears to reasonably account for the receipt and disbursement of prior year revenue and expenditure accruals. The accounts receivable accrual projection at the end of 2021-22 seems reasonable; however, the projection shows disbursement accruals only for certificated and classified salaries. The projection assumes all other expenditures are fully expended within the fiscal year. The projection shows expenditures of $7.03 million (40.8% of budget) in supplies and $28.3 million (45.6% of budget) in services in June 2022. 262 Financial Management 4. The district’s 2022-23 cash flow projection submitted with the adopted budget report does not show any revenue or expenditure accruals. The projection assumes that all revenues and all expenditures are fully received and expended within the fiscal year. The projection shows expenditures in supplies of $8.14 million (33.7% of budget) and expenditures in services of $13.1 million (27.2% of budget) in June 2023. 5. The cash flow projection submitted with the district’s 2022-23 first interim report appropriately accounts for the receipt and disbursement of prior year accruals. The projection also shows reasonable estimates of revenue and expenditure accruals at the end of the 2022-23 year. The cash flow projection was completed by a consultant. 6. District staff reported and county office staff confirmed that the county office balances the cash in the financial system with the county treasury. FCMAT was not provided with copies of the cash in county treasury monthly reconciliations. 7. The district does not reconcile the cash with fiscal agent bank account to the district’s financial records. The bank account balance on June 30, 2022 was $16,653.23 while the balance on the financial report shows $16,583.03. 8. Generally, the district deposits cash and checks received into a local bank account three to four times per month and transfers those monies to the county treasury at the end of the subsequent month. However, November receipts totaling $350,718.78 were not transferred to the county treasury until January 11, 2023. The district should make transfers of monies held in the clearing account into the proper fund on a timely basis, preferably weekly instead of monthly as is the current practice. 9. The district provided sample clearing account reconciliations for October, November, and December 2022. The October reconciliation was dated November 10, 2022, the November reconciliation was dated January 3, 2023, and the December reconciliation was dated January 18, 2023. Revolving fund reconciliations for October, November, and December 2022 were dated November 10, 2022, January 3, 2023 and January 17, 2023, respectively. Bank statement reconciliations should be completed within two weeks of the receipt of the statement, and based on the sample received, except for the month of November, the district is completing the reconciliations timely. The documents demonstrate the reconciliation of the general clearing and revolving cash fund accounts and include the name or signature of the individuals that prepared, reviewed and approved the reconciliations. 10. The revolving account reconciliation for January 2023 shows no outstanding checks issued from the account more than six months old. 11. The revolving account has an approved balance of $100,000. The reconciled balance in the account on January 31, 2023 was $82,859.99. Most of the transactions in the district’s revolving account are for salary advances or payroll errors. The outstanding balance on January 31, 2023 that was owed to the district by employees, former employees, and board members dating back to March 2014 was $14,717.20. Of that amount, $6,817.20 is for Financial Management 263 salary advances made between March 2014 and February 2021; $4,500.00 is from a salary advance made in June 2022; and $3,400.00 is from salary advances made in January 2023. An additional $2,422.81 in nonpayroll disbursements from January 2023 had not been reimbursed as of January 31, 2023. On May 26, 2022, the district wrote off $17,165.39 in uncollected salary advances dating back to February 2012. FCMAT found no evidence in board minutes that the county administrator/advisory board approved this write-off. Recommendations for Recovery 1. The district must work to eliminate the structural deficit in its unrestricted general fund and maintain a positive cash position. 2. The district should continue to verify its cash projections monthly and update them for the current and subsequent fiscal year as needed between budget and interim reporting periods. It should ensure that cash flow projections presented to the county administrator/ board are attached to the board agendas posted online for public access. 3. The district should continue to accurately account for revenue and expenditure accruals in the receipts and disbursements sections of the cash flow projection and should continue to account for the receipt of revenues and the disbursement of payables for prior year accruals in the balance sheet section of the cash flow projection. District staff should be trained to prepare the cash flow projection. 4. The district should make transfers of monies held in the clearing account into the proper fund on a timely basis, preferably weekly. 5. The district should reconcile the cash with fiscal agent account at least annually and ensure that the activity in the account is recorded in the financial records. 6. The district should continue to reconcile the revolving and clearing accounts monthly. Reconciliations should be completed shortly after the bank statements are available. 7. The district should continue to cancel and clear any stale-dated checks over six months old from its bank reconciliation monthly and remove them from the outstanding check list. 8. The district should follow up on all outstanding items shown on the revolving fund bank reconciliations, including outstanding advances to former board members and overpayments to employees. All attempts to contact people for repayment should be documented. County administrator/advisory board approval should be obtained for any amounts written off. 264 Financial Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 3 July 2017 Rating: 2 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 265 8.2 Accounting Professional Standard The LEA’s payroll procedures comply with the requirements established by the county office of education, unless the LEA is fiscally independent. (EC 42646) Per standard accounting practice, the LEA implements procedures to ensure timely and accurate payroll processing. Findings 1. As of the date of fieldwork, the Payroll Department was fully staffed, with one payroll manager, hired in October 2022, and two lead payroll technicians. The former payroll supervisor resigned in June 2022 after only one year in the position. The new payroll manager should be trained and given access to all payroll procedures in use in the district. 2. On August 10, 2022, the district approved a contract with a consultant to provide assistance in accounting and budgeting, including payroll, at a cost not-to-exceed $50,000. 3. Personnel requisitions are created and routed electronically for approval using the Informed K12 system, a digital workflow processing software. After approvals have been obtained, HR staff enters the information into the HRS system. Staff reported processing delays frequently occur when positions are not set up in the HRS system prior to the payroll deadline, causing manual payroll advances. Documents provided show that 64 handwritten checks were issued for missed payments in the current review period and varied from zero in one month up to 22 in another month. 4. The district uses the Frontline software system for absence reporting and substitute placement. Employees are expected to use the system to report their absences; however, in some cases, employees call or email the office managers to enter the absence in the system. School sites use sign-in sheets to record employee attendance and use the Frontline reports along with the sign-in sheets to create absence reports in Informed K12. The absence reports are routed electronically to the site administrator for approval and then to payroll. The lead payroll technicians manually transfer the employee absence information from the absence reports to a shared spreadsheet to record employee absences and track leave balances. Payroll meets with HR twice a month to review the leave balances and ensure that payroll docks are entered correctly. The district provided FCMAT with a blank copy of the monthly absence report reconciliation form. The form includes reconciliation procedures for both the lead payroll technician and the payroll manager with signature and date lines. However, no completed reconciliation forms were provided, so FCMAT cannot determine if the reconciliations were being performed. 5. As mentioned above, school sites use sign-in sheets to record employee attendance and total hours worked. School site office managers transfer the hours/days worked from the sign-in sheets and the Frontline reports to create timesheets. Timesheets are created and routed for approval using Informed K12. The site principal approves the timesheets, which are then routed to HR for approval, and then to payroll. This electronic system allows staff to track the form throughout the approval process. Staff reported that some timesheets are 266 Financial Management not submitted by the payroll deadline for processing, causing manual payroll advances. Some departments still use a manual paper process for timesheets. In the prior review period, staff reported that a signature stamp was used in one department on timesheets. FCMAT could not determine whether this practice was still in use during the current review period. The use of a signature stamp should not be permitted, as use of a stamp does not ensure that the supervisor reviewed and approved the hours worked. The lead payroll technician compares the timesheets to the position and rate information in HRS. In addition, the technician prints the certificated and classified personnel rosters that are presented on the board agenda each month to check for approval of personnel items. During the prior review period, the district implemented the use of a spreadsheet, which was maintained on the shared drive. The purpose of the spreadsheet was to minimize the number of manual paychecks when employee changes are not entered timely in the sys- tem. HR staff entered payroll changes on the spreadsheet, and payroll staff checked it for changes before processing payroll to ensure the most updated information was included. The spreadsheet is no longer in use. Staff interviews indicated that the district plans to implement the time and attendance feature of the Frontline software system, which will allow for electronic timekeeping and eliminate the need for manual sign-in sheets. Processing timesheets is cumbersome, requiring many hours of manual processing and verification. To avoid manual processing and potential for errors, the district should follow through with the implementation of an electronic process. 6. Interviews with staff indicated that any overtime hours worked must have preapproval, and the preapproval form is routed through Informed K12. After approval, the preapproval form is attached to the timesheet and sent to payroll. However, staff reported that the process is not always followed, and payroll staff are sometimes directed to process overtime timesheets without the preapproval form. Management override of established processes represents a weakness in internal controls and undermines the authority of midlevel supervisors. 7. BP 3314-Payment For Goods And Services, states that “Newly budgeted positions shall be approved at a Board meeting prior to filling the position. Payroll for new employees hired in open positions shall be processed with ratification of the employment occurring at a regularly scheduled Board meeting.” The district does not follow this board policy. All employment actions (new hires, including those hired for vacant positions, extra duty assignments, and extra hour assignments) must be approved by the county administrator/ board before the employee can be added to payroll. Staff at one site reported that two employees had worked three extra hours each day for the past two months and had not been paid for their time as of the date of FCMAT’s fieldwork. The payroll procedures manual should be updated to reflect this policy, and the policy should be discussed with HR and Payroll staff to avoid confusion and ensure that it is implemented. Financial Management 267 8. The district did not provide FCMAT with a payroll manual, but staff indicated that various HRS system procedure manuals are used by staff to process payroll. The district is still working on developing a comprehensive Business Services Department procedure manual, and the payroll section has not yet been completed. The district provided FCMAT with forms and instructions regarding some payroll processes. The new payroll manager indicated that he is working on developing a payroll manual and has started an electronic file of “How-to” documents. The payroll manager should be provided with all processes, procedures, and forms that have been utilized by the Payroll Department to use as a starting point in the development of a payroll manual. 9. FCMAT continues to recommend that the district adopt a board policy to address payroll overpayments and identify repayment methods. During this review period, FCMAT was not provided with documentation to substantiate that such a policy was created. The district’s agreement with its former classified bargaining unit stated that payroll overpayments will be collected by automatic salary deduction in equal installments over 12 months. FCMAT was not provided with the current classified bargaining agreement. Additionally, some general interdepartmental procedures have been developed to guide staff members with the issuance of payroll advances; however, the procedures do not include details on the collection of overpayments. A detailed list of overpayments is no longer maintained, so FCMAT cannot determine whether any overpayments were made in the current review period. 10. The letter used by the district to notify employees of a salary overpayment notes the amount, how much will be deducted over the next number of months, and the date the deductions will begin. However, the letter is missing key elements including the date(s) of overpayment, the reason for the overpayment, an offer to meet with the employee and review the issue, a deadline to respond to the letter, and a place for the employee to sign and date his or her acknowledgement of the salary overpayment and repayment method. A best practice is to develop and implement a form letter to notify employees of an overpayment that clearly communicates all information pertinent to the matter. 11. The district has no written procedure on how to process payroll advances for missed documents or payroll errors. Based on interviews with staff and documents provided to FCMAT, employees may request a manual check if they do not receive a paycheck for their work on their scheduled payday; the district calls these manual payments “payroll advances.” The district’s agreement with its former classified bargaining unit requires the district to issue a check for 70% of the gross salary amount if an employee’s regular monthly paycheck is not available on the scheduled payday. The bargaining agreement expired on June 30, 2021, and the district did not provide the current agreement to FCMAT. In some cases, the Payroll Department calculates the hours to be paid from a timesheet or time report and writes a check from the revolving account for 60% or 80% of the gross amount to allow an estimated amount for taxes (each lead payroll technician uses a differ- ent amount for the calculation). The amount advanced is repaid by a miscellaneous deduc- tion from the employee’s next paycheck. Fourteen of the 27 payroll advances issued by the district in September, October, and December 2022 were repaid through a miscellaneous deduction from the employees’ next payroll warrant. In other cases, the district uses the fi- 268 Financial Management nancial system to calculate the exact amount of taxes, statutory benefits, voluntary deduc- tions, or garnishments, if any, that should be withheld from the gross pay. The employee receives a revolving fund check for the calculated net pay, and the paycheck is processed payable to the employee but deposited into the district’s revolving fund account. Thirteen of the 27 payroll advances issued by the district in September, October, and December 2022 were repaid with a paycheck payable to the employee and deposited into the district’s revolving fund. Employees sign a form acknowledging that they received an advance for a specified amount and that they agree to reimburse the district for the advance or allow the Payroll Department to deposit the payroll warrant, once it is available, in the revolving account. The district’s list of outstanding payroll advances, updated January 31, 2023, shows four payroll advances issued during this review period that are still outstanding, including one issued in June 2022 to a current employee for $4,500.00. As of January 31, 2023, 10 outstanding payroll advances issued between March 2014 and February 2021 totaling $6,817.20 remain uncollected. The risk of overpaying employees would be reduced if the district consistently entered a miscellaneous deduction on the employee’s next paycheck to reimburse the revolving fund. 12. In several previous reporting periods, FCMAT has recommended that the district establish administrative regulations to collect or write off payments due to the district if determined to be uncollectable. As discussed in Standard 8.1, a review of the revolving fund as of January 31, 2023 indicates $14,717.20 in payroll overpayments were outstanding, some dating back to March 2014. Absent board policy and county administrator/board approval to write them off, these uncollected payments may represent a gift of public funds. In May 2022, the district wrote off $17,165.39 in uncollectable salary advances; however, it did not provide FCMAT with documentation of its attempts to collect or county administrator/board approval to write off the advances. 13. Payroll can modify withholding information on the payroll system; each lead payroll technician changes any applicable deductions related to his or her payroll, stamps the initiating document and files it. Employee-initiated modifications are not reconciled to computer-generated payroll withholding reports. 14. Internal controls for payroll should provide the appropriate checks and balances between departments and segregation of duties in the business office. Proper internal controls ensure that the employees who process payroll are not authorized to sign the payroll warrant list or have access to the pay warrants received from the county office. Payroll warrants are delivered from the county office to the Payroll Department, and each lead payroll technician sorts and prepares the checks he or she processed for mailing or delivery to employees. The district should assign a business office employee not involved in the processing of payroll to receive and distribute payroll warrants. 15. The payroll manager audits or reconciles the payroll listing prior to submission of the payroll warrant list to the county office. The district provided written procedures for reconciliation and review of the payroll by the lead payroll technicians and the payroll manager prior to executing the final payroll warrant register. The district should designate Financial Management 269 another supervisor in the business office to perform this task if the payroll manager position is vacant. As a secondary review process, another manager in the Business Services Department should review the final payroll register and check cash balances before payroll is submitted to the county office. 16. Interviews with staff indicated that fund 76, the payroll warrant pass-through fund, has not been reconciled in several years. Regular reconciliation of the payroll clearing accounts would ensure transactions are recorded properly and prevent possible misstatement in the financial system. During this reporting period, the district used a consultant to reconcile the balance sheet accounts, including the payroll clearing accounts in fund 76. As a result of the reconciliation, the consultant proposed a restatement to the fund totaling $793,585.56. The district’s 2021-22 audit report contained a finding stating that the district’s failure to reconcile the payroll accounts resulted in the district not recording OPEB retiree benefits on the district’s year-end financials. 17. Payroll staff attend training events hosted by the county office of education and should continue to attend these trainings to learn how to generate various county system reports that may identify potential payroll errors. Additional training should be provided to the newly hired payroll manager. Recommendations for Recovery 1. The district should train, and retain sufficient qualified staff in the Payroll Department to ensure payroll is processed accurately and in a timely manner, and proper segregation of duties and supervision occurs. It should ensure that consultants used by the district provide training to district staff to build internal capacity. 2. The district should ensure that personnel requisitions are initiated and electronically routed through the approval process and to payroll in an efficient and timely manner. HR staff should enter approved positions in the HRS system prior to the payroll deadline. 3. The district should enforce the use of the automated absence system by all employees at all sites. 4. The district should document the reconciliation process between the substitute-caller system, timesheets or payroll registers and its Excel spreadsheets to track absences for all employees, to ensure that the data entry is correct. All payroll-related transactions should be reconciled, and reconciliations should be reviewed and signed by a supervisor. 5. Supervisors should ensure that timesheets are submitted to payroll in a timely manner, on or before the payroll processing deadline to reduce the number of manual payroll checks. All sites and departments should use the Informed K12 system to create and route timesheets to payroll. 6. The district should eliminate the use of manual timesheets and require all sites and departments to use the electronic system. 270 Financial Management 7. The district should prohibit the use of a signature stamp on timesheets. 8. The district should pursue implementation of electronic timekeeping software to avoid manual processing and potential for errors. 9. The district should ensure that it adheres to policy requiring preapproval for all overtime hours, and management should not allow supervisors to circumvent the established procedures. 10. The HR and Payroll staffs should be provided with BP 3314 regarding board approval of new positions prior to filling them and authorization to pay new employees who are filling open positions; the board should subsequently ratify these. The district should ensure the policy is understood, and employees should be held accountable for following it. The payroll procedures manual should also be updated to reflect the revised policy. 11. A payroll procedures manual should be developed and reviewed and updated as needed, at least annually, to provide guidance and consistency in the performance of payroll duties. The payroll manager should be provided with the processes, procedures and forms in use in the department. 12. The district should adopt board policy addressing payroll overpayments to staff and the measures that will be taken to obtain repayment, and/or those for the county administrator/board to write off payments due to the district. 13. The district should reestablish the practice of maintaining a detailed list of payroll overpayments, ensuring it is regularly updated. 14. The district should develop and implement a form letter to notify employees of an overpayment and clearly communicate all pertinent information. 15. A procedure to process payroll advances should be written with clear instructions of how to use the payroll system to generate the correct deductions from the gross manual payment to avoid overpaying employees. The procedure should address how to process the reimbursement of manual payroll checks by running the pay on the next county payroll cycle and entering a voluntary deduction payable to the Inglewood Unified School District for the amount of the manual check. To avoid overpayment, this process should generate a check for deposit back into the revolving account, and not another check to the employee. 16. The district should establish and implement administrative regulations and written procedures to seek the assistance of a collection agency to collect outstanding funds. 17. The district should review payroll procedures and implement additional internal controls, ensuring proper segregation of payroll duties, and ensure that payroll staff are monitored and supervised. Payroll warrants should not be returned to and distributed by the same employee that generated the warrant. Financial Management 271 18. The district should continue to follow written procedures for reconciling and reviewing the payroll prior to executing the final payroll warrant register. A manager in the Business Services Department should review the final payroll register and check cash balances before payroll is submitted to the county office. 19. The business office should ensure that all payroll staff know how to generate payroll error reports within the financial system and are trained to use them. Additional training should be provided to the new payroll manager. 20. The district should review overtime payments and add additional approvals if needed to eliminate any excessive overtime. 21. The district should provide regular oversight of payroll tax processing to ensure that payroll tax reports are filed, and payments are made accurately and timely. 22. The district should reconcile fund 76, the payroll warrant pass-through fund, and all payroll clearing accounts monthly. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 272 Financial Management 9.2 Attendance Accounting Professional Standard School sites maintain an accurate record of daily enrollment and attendance that is reconciled monthly. School sites maintain statewide student identifiers and reconcile data required for state and federal reporting. Findings 1. Student enrollment and attendance is the responsibility of the executive director of student support services under the leadership of the county administrator. State attendance reporting remains assigned to the accounting specialist who reports to the director of fiscal services in the Business Services Department. Several individuals are assigned responsibility for overseeing different student enrollment and attendance functions as follows: • Principals: oversee school site office staff responsible for collecting new student registration data and documentation from parents when enrolling students and teachers who are responsible for daily attendance. Principals are also responsible for reviewing and certifying monthly attendance reports that are forwarded to the Business Services Department for state attendance reporting purposes. • Elementary school sites are staffed with an office manager and a clerk/ typist II. Secondary school sites are staffed with an office manager, a clerk/typist II, a registrar and an attendance clerk based on the size of the school. • Clerk/typist II: at elementary school sites, this position is responsible for collecting student enrollment documents and entering and maintaining the new student data in the student information system (SIS). This position is also responsible for identifying and correcting errors and anomalies identified during the CALPADS state reporting process. For secondary school sites, these tasks are distributed between a clerk/typist II and the registrar. • All teachers are required to record attendance in the Aeries SIS daily. The clerk/typist II at elementary school sites and the attendance clerk at secondary school sites are responsible for monitoring teachers’ daily attendance to ensure they are recording attendance each morning, modifying student attendance in the SIS for late arrivals and/or absence verifications, collecting certified attendance reports from teachers each week, and preparing monthly school site attendance reports. • The executive director of secondary education oversees the short-term independent study program in concert with school site principals. Financial Management 273 • Executive director of special education oversees one data teacher on special assignment (TOSA) responsible for enrollment data in the SIS for students with IEPs and reconciling that data with the data in the SEIS. The TOSA is also responsible for managing enrollment data for students attending NPS, which is based on information provided by NPS providers when invoices are submitted to the district for payment via the established email list. • The executive director of student support services is responsible for overseeing school site attendance and alternative program attendance (i.e., long-term independent study and home hospital). This position is supported by one counselor position responsible for overseeing long- term independent study and a student support specialist responsible for overseeing the district’s Student Attendance Review Team (SART) and Student Attendance Review Board (SARB) truancy programs. The department’s ADA attendance clerk monitors school site attendance and notifies school site administrators of any teachers not meeting the daily attendance requirements; prepares and sends first truancy letters for all school sites; and assists with enrollment and processing interdistrict applications. • The executive director of IT oversees a database administrator who is responsible for CALPADS reporting. The database administrator works with district administrators, the data TOSA, registrars, attendance clerks and/or clerk/typist IIs to reconcile data between multiple systems including the SIS (Aeries), child nutrition software (Nutrikids and Titan), student testing systems, and teacher data in the position control and payroll systems. This position also identifies and oversees the correction of all errors or anomalies in student data identified through the CALPADS reporting process. • The accounting specialist is responsible for state attendance reporting. The district has made progress in establishing consistent practices for managing student enrollment and attendance across all school sites. However, weaknesses still exist for rec- ognizing and entering student enrollment and daily attendance data in the SIS for students identified as requiring special education services and attending nonpublic schools. There were inconsistencies in what staff reported about how the district manages attendance for home hospital and NPS students. It is essential for attendance to be overseen by one individual knowledgeable of and/or experienced in all aspects of student enrollment and attendance requirements. The dis- trict continues its struggle to ensure all elements contributing to state funding are fluid and accurate from the point of enrollment through state reporting. While some evidence indicates collaboration, the existence of isolated functions and the lack of reconciliation processes between all contributing segments remain. 274 Financial Management 2. The primary source of school district funding is state apportionment based on the LCFF. The LCFF calculations use ADA in the P-2 and annual certified attendance and unduplicated pupil enrollment certified in CALPADS. Accurate and timely enrollment and attendance accounting is essential to ensure the district receives its appropriate level of funding. Because school district funding levels are directly tied to student enrollment data, including elements related to the unduplicated pupil counts and ADA, the accuracy of the data reported to the state through CALPADS and attendance report submissions is extremely important. While progress has been made, the district continues to struggle to ensure that all data elements contributing to the unduplicated pupil count, including free and reduced-priced meal eligibility and ELL designation, are collected and entered into the SIS timely. 3. Interviews indicate that while the district has improved some of its processes for identifying students attending and exiting nonpublic schools and ensuring they are enrolled or exited in the SIS, staff continue to note students listed on NPS invoices that are not enrolled in the SIS and vice-versa. 4. The Special Education Department is responsible for entering into the SIS all enrollment data for preschool special education students and all students attending nonpublic schools. Services with NPS providers are based on each student’s IEP and/or 504 plan. Identification of or changes in NPS student status commonly occurs through data reconciliations between the SIS and the SEIS systems and through NPS provider invoices, which are submitted to the district by the service providers using a district established email address. Student data in the SIS is reconciled with data in the SEIS to identify missing and/or inaccurate data in the SIS. Staff in the Special Education Department do not enter attendance for NPS students into Aeries. The accounting office continues to use the ADA reported on the attendance registers that accompany the NPS provider invoices for state reporting purposes. These are often the same documents used by staff in the Special Education Department for new students attending NPS; as such, they come after the student has been receiving services. As a result, enrollment and attendance are not timely, may contribute to errors in CALPADS and attendance data submissions and could contribute to loss of LCFF funding. A lack of communication remains between all departments and sites responsible for different aspects of student enrollment and attendance, and there is no active administrative oversight that ensures cohesive enrollment and attendance processes through all segments. 5. Teachers must take attendance in compliance with the CCR, Title 5, Section 401, (a)–(d), which states: (a) Elementary school attendance shall be kept in a state school register, as required by section 44809, except when a central file is maintained as authorized by Edu- cation Code section 44809. Financial Management 275 (b) High school attendance (including junior high school) shall be kept on forms approved by the California Department of Education. (c) In all high schools, except those listed in (d) of this section, each teacher shall be required to submit to the principal, at least once each school day, a report of attendance for each period of the day in which he conducts classes, listing the names of all pupils absent in any period. (d) In all classes for adults, continuation schools, and classes, and regional occu- pational centers and programs, attendance shall be reported to the supervising administrator at least once each school month. Attendance reports that identify the status of recording daily and/or period-by-period (if applicable) attendance should be consistently run each day. Principals should follow up when a teacher does not follow procedures and hold him or her accountable for accurate, timely attendance. Principals should aggressively enforce the established time frame for teachers to record attendance each day. The Aeries system should be configured so that once this time period has passed, teachers are prevented from entering or modifying at- tendance for that day and must confirm attendance directly through the attendance clerk or front office staff. In this way, the principal will be made aware of those who are not recording attendance timely. Interviews with school site staff responsible for attendance indicated that teachers enter attendance into Aeries daily. The clerk/typist II and attendance clerks verify that teachers enter attendance each day; for elementary school sites attendance is entered into the SIS by a set time each morning, and attendance personnel later run a verification report to verify attendance has been taken. Middle school and high school attendance verifications are performed once at the end of each day for all periods. Parent/doctor notes for absences are forwarded to the school office. The Student Support Services Department monitors daily attendance at all school sites. A daily attendance report is run and distributed to all school site and district administrators each day by the department’s ADA attendance clerk. This continues to improve account- ability for ensuring teachers fulfill their responsibility for following attendance procedures and principals for monitoring daily attendance activities. 6. School site personnel reported that students who come to school late must report to the school office before going to class to ensure that attendance records are accurately updated. For secondary schools, school site attendance clerks revise attendance in the SIS as appropriate and provide the student with a slip to admit them to class. For elementary schools, staff in clerk/typist II positions are responsible for modifying attendance codes in the system based on parent and doctor notes submitted to verify absences and late arrivals. 7. Short-term substitute teachers that do not have access to the Aeries system are instead provided with manual attendance rosters for recording attendance. The manual registers are signed by the substitute teacher. Attendance documented manually by substitute teachers is recorded in the SIS by school office personnel. 276 Financial Management 8. The district has an established process for enrollment and attendance for students participating in the home hospital program. However, interviews indicated inconsistencies in the program’s administration, which could result in inaccurate attendance reporting for funding purposes. When assigned to the home hospital program, a student is designated as such in Aeries by the student’s home school. The Student Support Services Department assigns the student to a home hospital teacher and prepares a manual attendance register for that teacher, who reports the days and hours instruction was provided to each student. Interviews indicated that the home hospital teachers submit signed weekly reports to the teacher of record, who then enters the attendance into the SIS. The accounting specialist uses the attendance recorded in the SIS for state attendance reporting purposes. School sites reported students assigned to the home hospital program for this review period; however, the district reported no corresponding home hospital attendance for the P-1 reporting period. 9. No changes have been made to the following described procedures for completing each reporting period (P-1, P-2 and annual), which include reconciliation and review of monthly reports generated by the school sites with the districtwide system reports before submission to the state. Teachers print and certify weekly attendance registers. Monthly classroom attendance certification reports are printed from the SIS at the end of each school month and are signed by the teachers and retained at the school sites. The school sites print monthly school site attendance reports, principals sign them, and copies are forwarded to the district office accounting specialist for state attendance reporting purposes. The accounting specialist enters the monthly attendance data for each school site and other programs into an Excel workbook, which then consolidates attendance for state attendance reporting for each reporting period. Interviews indicated some inconsistencies in practice from the district’s established procedures (e.g., one school site reported that teachers did not sign monthly classroom attendance certification reports). The district’s 2021-22 audited financial statements contained one audit finding regarding P-2 and annual certified attendance for both the district and La Tijera Charter School. The report indicated the district used an incorrect extended year special education divisor in its calculation, and that both the district and La Tijera Charter School did not capture attendance corrections in the P-2 attendance reports, resulting in potential unallowable ADA funding of $1,408 and $9,664 respectively. 10. Interviews with staff indicated that school months are kept open all year in the SIS. The accounting specialist routinely reviews attendance from previous months to identify any changes made by school site staff after attendance has been submitted to the state. When changes are identified, all reports are rerun and recertified by the school site. A best practice is to close school months after certification of attendance is completed, so revisions to attendance data are controlled. Once an attendance month is locked, sites may view the information, but cannot change the data. The school site attendance clerk must identify any necessary changes and request the school month to be reopened so school site personnel can make corrections and recertify attendance for that period. Permissions can be established to allow access to those responsible for recording attendance earned through attendance recovery programs as they are certifying that attendance. When corrections are necessary, all reports for the period should be rerun, recertified, and retained for an audit to ensure state-reported attendance is accurate, and supporting documentation accurately depicts certified data. Financial Management 277 11. The IT Department, under the leadership of the executive director of IT, is responsible for managing and supporting the SIS, reconciling data between the SIS and other systems of original entry, and complying with CALPADS reporting requirements. The district has established processes for researching data elements reported in CALPADS and resolving errors and anomalies before data certification. The IT Department has established reconciliation procedures for each of the multiple systems used to capture student data including Aeries, Nutrikids, Titan, Test Operations Management System, and teacher data in the position control and payroll systems. Processes to transfer data from some systems into the SIS for CALPADS reporting have also been established. For example, student data flows between Aeries, Nutrikids and Titan through nightly imports, and data is transferred electronically from SEIS to Aeries. After significant turnover and restructuring in the prior year, the department continues to experience operational limitations resulting from vacancies in key positions (i.e., database administrator and application support technician). These ongoing vacancies and staff members with limited experience with the district’s processes, contributed to difficulties in reconciling data and not meeting CALPADS reporting timelines during this review period. 12. It is essential to have board policies, operational procedures, desk manuals and routine training for staff members with duties that involve enrollment and attendance tasks. The district has a comprehensive enrollment and attendance procedures manual and numerous detailed standard operating procedures (SOPs) containing instructions on student enrollment and attendance. The district should routinely review and update the manual and established procedures. The IT Department continues to work with department and school site staff where necessary to ensure data collected in individual systems outside of the SIS is uploaded or otherwise entered into the SIS. Staff continue to rely on established procedures for recording data and training district and school site personnel. Sites continue to report similar practices in core daily enrollment and attendance activities and the process for identifying CALPADS reporting errors. Interviews with staff responsible for entering student enrollment data into the SIS indicated that correcting coding errors and anomalies has become routine. School site personnel acknowledge the existence of procedures for completing associated tasks. However, new school site personnel report that more extensive training would be appreciated since they have had to primarily rely on their peers to learn how to complete their work; experienced school site personnel report that an opportunity to meet more regularly, such as monthly, would be helpful to discuss changes or nonroutine issues and ensure consistency in practices districtwide. The Enrollment and Attendance Procedures Manual and standardized detailed instructions should be distributed and/or reviewed at the beginning of each school year with principals, assistant principals, school site clerical and support staff, attendance and IT support staff, and any applicable district office staff. These tools provide the schools with consistent reference sources to use in performing their duties and provide district office attendance staff and administrators with the guidelines to hold staff accountable for the proper recording and accounting of daily student attendance. 278 Financial Management Recommendations for Recovery 1. The district should continue efforts that ensure effective procedures for reconciling information between CALPADS and Aeries are established and followed. 2. The district should ensure routine reconciliations are performed between all segments contributing to student enrollment and attendance reported through CALPADS and state attendance reporting. One individual should be responsible for ensuring accuracy of all student data and attendance for and between all programs including home hospital, short- term and long-term independent study, nonpublic schools, Saturday school and general school attendance. 3. The Enrollment and Attendance Procedures Manual and desk manuals or SOPs should be reviewed at least annually and updated as needed. 4. The district should distribute the procedures manual and any other written procedures to all staff members responsible for student enrollment and attendance tasks, and an annual review of fundamental procedures and updates should be provided. In addition, it should provide training to new site staff and additional opportunities for all staff members responsible for enrollment and attendance to meet regularly to discuss changes or issues and to ensure consistency in practices districtwide. 5. The district should continue monitoring daily attendance, holding all teachers and administrators accountable for the duties of completing accurate attendance records. 6. The district should require NPS providers to forward official attendance to the Special Education Department at the end of each week. The attendance reported on these registers should be entered in the Aeries SIS upon receipt. Attendance reported on invoices submitted by NPS providers should be compared to the attendance reported and recorded in the SIS. 7. The district should continue efforts in establishing standardized practices for managing enrollment and attendance for students attending nonpublic schools. The district should ensure that student enrollment is entered into the SIS in a timely manner and attendance is accurately reported to the state. 8. The district should routinely monitor standardized practices for managing enrollment and attendance for students attending all programs, ensuring that data is entered into the SIS accurately and in a timely manner. 9. The district should configure the SIS access schedule to limit the ability for entering and/ or editing student attendance, ensuring that teacher access ceases after a predetermined time each school day and that school site attendance clerk access ceases upon certification and closure of each school month. 10. The district should ensure that staff are sufficiently trained and cross-trained in CALPADS reporting procedures so CALPADS reporting timelines are met and reports are accurate. Financial Management 279 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 5 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 280 Financial Management 9.3 Attendance Accounting Professional Standard Policies and regulations exist for independent study, charter school, home study, inter-/intra-LEA agreements, LEAs of choice, and ROC/P and adult education, and address fiscal impact. Findings 1. The district has established board policies and administrative regulations attributable to this standard including: • BP and AR 5116.1-Intradistrict Open Enrollment, revised February 20, 2019 • BP and AR 5117-Interdistrict Attendance, revised April 22, 2020 • BP and AR 5118-Open Enrollment Act Transfers, adopted August 4, 2014 • BP and AR 6158-Independent Study, revised August 24, 2022 and August 11, 2021 respectively • BP and AR 6181-Alternative Schools/Programs of Choice, adopted August 4, 2014 • AR 6183-Home and Hospital Instruction, revised April 17, 2019 • BP and AR 6200-Adult Education, revised February 20, 2019 Because the district has established and follows a policy for open enrollment, which allows resident students to enroll in any regular, grade-appropriate Inglewood Unified school, it no longer uses intradistrict permits. 2. BP and AR 6158 address independent study. The district continues to operate indepen- dent study programs offered to students upon request when absences are for three or more consecutive school days in accordance with EC 51747. Parents may request that their student be placed on independent study by completing an application and agreeing to the terms of the contract. As a result of the pandemic and changes in long-term independent study, the COO had provided oversight of the program during the prior review period. However, subsequent organizational changes, including the elimination of the COO position, have led the district to split the independent study program as of January 2023 between the executive director of student support services, who oversees the long-term independent study program, and the executive director of secondary education, who over- sees the short-term independent study program in concert with school site principals. 3. State attendance regulations for independent study are stringent and require the school, parents, and teachers to follow each element of the agreement in a particular order. It is essential to ensure that both independent study programs comply with all program rules and regulations to avoid loss of apportionment funding. The 2021-22 audited financial statements contained two audit findings regarding the district’s independent study pro- gram, which could result in financial penalties. Specifically, the audit identified contracts Financial Management 281 that were not signed timely by all parties, missing work samples, and contracts for less than three days at the La Tijera Charter School, which led to disallowed ADA for fund- ing purposes. The audit report also indicated the district did not calculate its independent study ratio to ensure the accuracy of its reported eligible ADA pursuant to EC 51745.6. 4. The district has established AR 6183-Home and Hospital Instruction, which offers indi- vidual instruction for students with a temporary disability that makes school attendance impossible or inadvisable. Parents must provide physician documentation supporting the illness or limitation. Students are matched with a teacher who works directly with the stu- dent’s assigned teacher for coursework then goes to the student’s home or hospital location to provide instruction. Interviews indicated inconsistencies in the program’s administra- tion, which could result in inaccurate attendance reporting for funding purposes. School sites reported having students assigned to home and hospital instruction in the SIS; how- ever, the Student Support Services Department, responsible for the program’s oversight, reported no attendance for the P-1 reporting period. 5. The district does not have board policies or administrative regulations specific to charter school attendance. District-operated charter school attendance procedures are consistent with noncharter schools in the district; the charter school is simply set up in the SIS as another school site for recording student enrollment and attendance. Recommendations for Recovery 1. The district should adjust its practices and oversight related to independent study to ensure compliance with required elements of the independent study agreements, student work, and student attendance reporting practices. 2. The district should adjust its practices and oversight related to home and hospital instruction to ensure student attendance reporting is accurate and timely. 3. The business office should perform periodic internal audits to test the validity of attendance reported for apportionment including independent study, home hospital and district-operated charter school programs. 282 Financial Management Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 7 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 283 9.4 Attendance Accounting Professional Standard Students are enrolled and entered into the attendance system in an efficient, accurate and timely manner. Findings 1. Parents initiate student enrollment either by submitting an online application or completing an application at the school with the assistance of school site personnel. Required documentation is either attached with the online application or brought to the school to complete the registration process. School site office staff use a standardized student enrollment checklist to complete the enrollment process, following up directly with parents to obtain any missing documentation. Each school site has a dedicated position, either a clerk/typist II or registrar, who enters and manages student enrollment data in the SIS. 2. Enrollment for students with special circumstances (e.g., IEPs, home hospital, etc.) is initiated at the student’s resident school where the required enrollment documents are collected, then the parent is directed to either the Special Education or Student Support Services department when necessary for placement determination. Interviews indicate inconsistencies in how school site clerks collect IEP information through the enrollment process; this has delayed identifying some students requiring special education services. 3. The special education data TOSA reviews data for special education students in the SEIS system and reconciles it against data in the SIS and CALPADS. 4. The district contracts with numerous NPS providers for services for some students with IEPs or 504 supplemental service plans. Staff members in the Special Education Department continue to work on improving processes to identify missing student information and data errors in Aeries and reconciling information between multiple special education systems not integrated with the SIS. The district has established an email address, which it requires NPS providers to use to submit invoices. The special education data TOSA and the accounting specialists all receive copies of the NPS invoices, which are used by each to complete various tasks including verifying students in SEIS and Aeries, verifying services provided against the IEP and capturing attendance. While improvements have been made to district processes to mitigate issues, the district continues to struggle to ensure that the SIS data is updated in a timely manner for all students attending or exiting nonpublic schools. Interviews with staff continue to indicate that students noted on NPS provider invoices are not always found in Aeries when completing state attendance reports. As a result, student enrollment data, apportionment attendance, and unduplicated pupil counts all may contain errors. 284 Financial Management Recommendations for Recovery 1. The district should monitor the implementation of established procedures that require stu- dent enrollment information to be entered into the SIS at the time of registration or as soon as possible following parent submission to ensure each student is recognized in the SIS and correctly assigned to a classroom so that daily attendance accounting is accurately reported. 2. The district should ensure that school site staff follow consistent practices when enrolling stu- dents with special needs to ensure that all students receive appropriate services without delay. 3. Staff responsible for managing student data, including CALPADS reporting, should clearly understand how the student data is used throughout the district, including funding, stu- dent testing, and special education services. 4. The district should continue improving procedures for obtaining, entering into the SIS, and reporting enrollment data for students attending NPS to ensure data is captured and entered into the SIS accurately and timely. 5. The district should monitor all enrollment and attendance tasks and ensure that data is properly captured for both enrollment for CALPADS reporting and attendance for state apportionment reporting. 6. The district should continue practices of routinely reconciling data in the SIS, SEIS, and CALPADS, including data for students enrolled in alternative programs such as NPS. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 1 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 285 9.6 Attendance Accounting Professional Standard The LEA utilizes standardized and mandatory programs to improve the attendance rate of pupils. Absences are aggressively followed up by LEA staff. Findings 1. Under the direction of the county administrator, the executive director of student sup- port services oversees district school site attendance and manages student services and programs, such as long-term independent study and home hospital. Programs related to student discipline, suspension and expulsion including the SART, Resource Panel and SARB are also managed under the leadership of this position. 2. The district has established board policies and administrative regulations to support stu- dent attendance, and many were last updated in February 2019. BP and AR 5113.1-Chron- ic Absence and Truancy, clearly define the responsibilities and methods for identifying and addressing chronic absenteeism. AR 5113.1 also states that habitual truants may be referred to a SARB, and BP and AR 5113.12 speak specifically to the SARB process. The district continues its efforts to reinstate all practices to address chronic absenteeism, in- cluding the SARB; many of which had been suspended during the prior review period due to the COVID-19 pandemic’s impact on student attendance. 3. The district continues to use School Messenger, an automated notification service integrated with the district’s student information system, that quickly delivers large volumes of messages through multiple channels for parent notifications, including notification of student absences. This allows for timely and efficient parent notification when a student absence is recorded. 4. The Student Support Services Department manages attendance intervention services. Progres- sive intervention for addressing chronic absenteeism is initiated by the ADA attendance clerk who is responsible for preparing the first truancy letters, which are sent to parents when a student has three or more unexcused absences. Copies of the letters are sent to the school site administrators who are responsible for mailing subsequent truancy letters to parents/guardians and proceeding with site-based intervention through the SART process if absences continue. The district provided FCMAT with copies of the letters and interviews indicating that the school site administrators were following up with parents. School sites are responsible for monitoring student attendance and documenting intervention steps taken throughout the SART process and up until absenteeism reaches the point of a referral to SARB. Once a referral has been sub- mitted, the Student Support Services Department personnel manage the SARB process. 5. BP 6176-Weekend/Saturday Classes, revised February 20, 2019, establishes the framework for the district to conduct makeup classes that include but are not limited to those for unexcused absences occurring during the week (EC 37223). The program was temporarily discontinued in the 2018-19 school year, and due to the COVID-19 pandemic, the district had not resumed Saturday school program activities during this review period. However, it was actively planning to restart the program as soon as January 2023 as an instructional strategy and to recover apportionment ADA lost due to absenteeism. 286 Financial Management 6. Interviews indicated the district’s chronic absenteeism for the current school year is close to 38%; the Student Support Services Department is focusing on strategies outlined in the district’s 2021-23 Instructional Plan to meet the 2018-23 Strategic Plan goal that at least 19 of every 20 students (95%) will have a 95% attendance rate. In addition, the district reorganized the department’s leadership to report directly to the county administrator. Recommendations for Recovery 1. The district should monitor the implementation of established truancy processes and procedures performed by school site personnel. 2. The district should continue working with students, parents and the county district attorney’s office to enforce attendance policies. 3. The district should continue monitoring practices followed at all school sites to ensure all SART/SARB procedures are consistently followed. 4. The district should continue with its plans to resume a Saturday school program, and ensure it uses the program for attendance recovery as well as instructional support. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 3 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 287 9.7 Attendance Accounting Professional Standard School site personnel receive periodic and timely training on the LEA’s attendance procedures, system procedures and changes in laws and regulations. Findings 1. Routine mandatory training is essential to ensure those responsible for recording and monitoring student attendance understand laws and regulations. Training provides an opportunity for those staff members to discuss information on the best practices, clarify procedures, and communicate with district office staff on areas that may need refinement or district intervention. An annual overview of the purpose and procedures for recording daily attendance ensures all staff members understand their roles and responsibilities in the attendance process and the importance of standardized procedures. An annual overview of the attendance software serves as a refresher to the system and allows the opportunity for questions and clarity. Mandatory yearly training should occur before the start of each school year and should include attendance accounting procedures, compliance requirements, and internal controls. Training should be structured to target the different areas of responsibility including district attendance accounting, school site attendance and teacher daily attendance. Additionally, new staff members responsible for recording the official attendance should receive adequate training upon hire. A list of personnel required to attend should be used to document attendance, and accountability procedures should be established. Workshops such as those offered by CASBO on pupil attendance accounting for school site personnel and school district personnel are great options for partially fulfilling the need for training. The district conducted group trainings covering some student enrollment and attendance procedures for school site and department personnel. Interviews indicated that employees continue to have direct access to system tutorial tools to resolve their data entry problems. However, interviews also indicate that new school site personnel responsible for student enrollment and attendance do not feel they received adequate training when assigned to their positions. Most reports indicate that staff members self-initiate collaboration with other staff members when confronted with work-related problems. 2. The district has moved away from monthly data management meetings with IT and school site staff historically used for group trainings. This practice has been replaced with individualized 1-on-1 meetings scheduled at the request of school site staff based on individualized needs for technical support about various enrollment data entry procedures, Aeries and CALPADS navigation tools used to identify and correct data entry errors, and duties assigned to data technicians and school site personnel with enrollment and attendance responsibilities. Interviews with staff responsible for entering and managing student data in the SIS indicated that these meetings are helpful to those 288 Financial Management who take the initiative to request a meeting, but many site staff do not. Most school site personnel report self-initiated collaboration with colleagues in similar positions at other school sites. Interviews with school site personnel indicated a strong interest in reestablishing the previous monthly meetings to share information and ensure consistency in practices districtwide. 3. The district has established written resource materials to support the daily duties of school site staff responsible for student enrollment and attendance. The district updated its comprehensive Enrollment and Attendance Reference Guide for the 2020-21 school year and distributed it to school site office staff and administration. The district did not provide FCMAT with an updated guide. The district also has a series of standard operating procedures referred to as “How To’s” located on its shared drive and accessible to all staff responsible for data entry and maintenance of student data in the SIS. 4. District administrators, including school site principals, should also receive annual training that ensures a clear understanding of the requirements regarding the school calendar, instructional days and required instructional minutes. All school site administrators should understand their responsibilities in ensuring that bell schedules, instructional days, and daily and annual instructional minutes comply with district policy and EC 46201. FCMAT was not provided with documentation supporting training for administrators and principals specifically focused on enrollment and attendance for the 2022-23 school year. 5. Interviews with school site personnel indicated collaboration between school office staff regarding student enrollment and attendance activities. However, all school office personnel should be cross-trained in enrollment and attendance procedures, so they can provide coverage when another employee is absent. Recommendations for Recovery 1. Training focused on student enrollment and attendance procedures, and Aeries attendance software should be required for all district-level staff members, school site staff, principals, teachers and IT Department staff with duties regarding student enrollment, attendance and/or CALPADS reporting. Training should be designed to ensure that proper procedures are followed consistently throughout the district, cover written attendance policies and procedures, and include any new laws and regulations on attendance and record-keeping requirements. 2. Mandatory training should be conducted for all school site and department personnel responsible for student enrollment and attendance before the start of each school year. Training should include an overview of all new attendance accounting procedures, and the importance of completing accurate attendance records for apportionment and auditing purposes should be stressed. Those absent should be held accountable to obtain the required training. Financial Management 289 3. The district should provide an annual overview of school site attendance procedures to school site administrators. Annual review should include any new changes in law or district-established procedures as well as training on the school calendar, instructional days and required instructional minutes. The district should ensure that all school site administrators fully understand the calendar and bell schedules as established for each fiscal year to ensure that instructional days and minutes comply with district policy and state requirements. 4. The district should reestablish routine meetings and training for school site staff responsible for enrollment focused on student data and CALPADS reporting. 5. The district should review, update, and distribute the comprehensive Enrollment and Attendance Reference Guide each year and provide a review of updates and revisions to school site staff. 6. The district should ensure that all school office personnel are cross-trained in enrollment and attendance procedures. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 2 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 1 July 2018 Rating: 1 July 2019 Rating: 1 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 3 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 290 Financial Management 10.4 Accounting, Purchasing, and Warehousing Professional Standard The LEA timely and accurately records all financial activity for all programs. GAAP accounting work is properly supervised and reviewed to ensure that transactions are recorded timely and ac- curately, and allow the preparation of periodic financial statements. The accounting system has an appropriate level of controls to prevent and detect errors and irregularities. Findings 1. Numerous changes have occurred in the Business Services Department over the last sever- al years. Since the last review period, the CBO resigned in June 2022 after holding the po- sition for less than two years, and a new CBO was hired in June 2022. The senior executive director of fiscal services resigned in July 2022, and a replacement was hired in October 2022. The director of fiscal services resigned in October 2022, and the facilities accountant was working out of class in the position at the time of fieldwork. The payroll supervisor resigned in June 2022, and a payroll manager was hired in October 2022. Even with these shifts and changes, some controls still exist to help prevent and detect irregularities. These controls include the following: • The county office HRS position control system was implemented several years ago. The district has worked to implement processes and procedures and ensure both Business Services, including Payroll, and HR depart- ments’ staff have been trained on position control. The Business Services and HR departments continue to have regular meetings to reconcile the data. • The district implemented the county office BEST financial system at the beginning of the fiscal year; however, the district has not yet transitioned to the BEST system for human resources and position control functions. • Budget reports are provided monthly to school site principals, and monthly meetings are held with principals to discuss budgets. Specific questions are discussed between business office staff and school sites at principals’ meet- ings, or at the sites’ request. School site principals indicated business office staff is available to assist when they have questions. Some sites track bud- gets and expenditures manually rather than using the financial system. Site administrators indicated they needed additional training on reading their budgets in the financial system. Department managers indicated they do not receive budget reports monthly, but only upon request. • Multiple approvals are required to process accounts payable transactions. • Journal entries require descriptions and backup, and a second-party re- view is part of the process. • A budget transfer form exists, and sites and departments can initiate budget transfers electronically using Informed K12. However, budget transfer re- quests are usually held and processed at the next interim reporting period. Financial Management 291 • The BEST accounting software prohibits the posting of unbalanced jour- nal entries. • Expenditures are reviewed to ensure sufficient funds (in total, by site or department) are available to cover current transactions; however, adequate controls are not in place to ensure individual accounts are not overspent. • Payroll procedures were designed to help prevent and detect unauthor- ized persons on the district’s payroll as well as overpayments and under- payments (see Standard 8.2). The payroll manager audits or reconciles each payroll before processing by the county office. • At the district office, two people count cash receipts together; however, some sites reported that even though cash is counted by multiple people, sometimes they count it individually rather than together. • The receipt of goods and services is ensured before payment is processed. • The county office processes all warrants, and one of the dual signatures is required to be from that office. The CBO approves purchase requisitions and all warrants online and is the second signature on all warrants. • Fully signed warrants that are scheduled for mailing are not left unattended. • The district has a substitute-caller system for all employees to contact when they are absent, reducing inappropriate payment when employees run out of available leave and providing better tracking of leave usage. • The accounts payable system is integrated with the purchase order system. • Interviews with staff indicated that employee accrued sick leave balances are included on payroll stubs. • There is an approved vendor list for withholding and payment of funds from pretax employee salary deductions for tax-sheltered plans and an- nuities. • Interviews with staff indicate that accounts payable staff do not have ac- cess to make changes in vendor screens, so they cannot add vendors or modify vendor information. • Interviews with staff indicate that payroll staff do not have access to add employees into the system. 2. The HRS system is not used to encumber payroll and benefits so sites cannot easily iden- tify what portion of their budget is committed to payroll expenses. Most site principals reported that they are sent a list of certificated and/or classified staff assigned to their campus to review two or three times a year, but one reported receiving it monthly. If the list has an error, the change is reported and generally made in the HRS system by the HR Department. The HRS system can encumber payroll, but under the present configuration, this would require completing and entering a purchase order for each employee with the appropri- ate account coding for salary and each of the statutory benefit classifications. At the end 292 Financial Management of each payroll cycle, the amount processed would need to be manually disencumbered. Because the probability of error from a manual system outweighs its benefits, the district cannot implement this internal control and budget monitoring mechanism with payroll. 3. The HR and Business Services departments meet monthly to determine which positions are to be eliminated and which are true vacancies in the HRS system. However, there is no documented procedure to ensure eliminated positions are removed from the HRS system as they occur, and position control is not reconciled with actual payroll. Staff in the HR and Business Services departments need additional training in position control. 4. The accounts payable system is integrated with the purchase order system. However, the system allows for duplicate payments if individual invoice numbers are not entered in the system. The new financial system will flag duplicate invoice numbers, but the system checks for duplicate invoice numbers across all vendors and is not limited to the current vendor in process. Interviews indicated that the BEST system includes a feature to check for duplicates for a given vendor rather than across vendors, and the district was planning to implement that feature. Accounts payable staff indicated that they always enter invoice numbers, and they also keep a manual log to track invoices that have been paid on open purchase orders. Manually tracking purchase order payments is time-consuming, and the accounts payable staff should use the financial system to track payments. 5. Based on a review of the 2021-22 general ledger, several journal entries were made for field trip expenses. The site budgets were overdrawn by these entries, and budget transfers to correct the negative balances were not made until year-end. A 2022-23 general ledger report dated January 25, 2023, shows no journal entries made to transfer the cost of field trips to sites; however, field trip expenditures have been incurred in the transportation resource. The California School Accounting Manual (CSAM) Procedure 640 requires that “other miles” (cost of transporting pupils other than home to school) must be transferred out of the pupil transportation function and charged as costs to the user program or proj- ect. Costs not transferred on a timely basis may cause site budgets to become overdrawn. 6. The district continues to experience insufficient segregation of duties for some tasks. The following areas are of concern, including some that are also audit findings: • Site custodians order necessary supplies from the warehouse; goods are delivered to the custodians, and the custodians sign for what was re- ceived. The same individual orders, receives and approves the custodial shipments, which is an insufficient segregation of duties and may provide opportunities for theft. This segregation of duties internal control is also missing with office managers in their order and receipt of office supplies. • Payroll and accounts payable warrants are returned to the same person who processed the transaction. • The district did not provide written procedures for the reconciliation of ac- counts receivable, and there was no evidence that outstanding balances were researched and reconciled. The 2021-22 audit report included a finding stating that the district could not provide documentation to verify some entitlement and grant allocations and that $1,759,231 of invalid receiv- Financial Management 293 ables that had been rolled over from previous years needed to be written off after the books were closed for 2021-22. The district hired a consultant to identify the balances to be written off. • The district provided no written procedures for the reconciliation of ac- counts payable, and there was no evidence that outstanding balances were researched and reconciled. The district’s 2021-22 audit report included a finding stating that failure to reconcile the payroll accounts has resulted in the district not recording OPEB retiree benefits liabilities on the district’s year-end financials, and the auditors identified a total of $4.37 million of accounts payable, which needed to be written off. The district hired a consultant to identify the balances to be written off. • A review of the 2021-22 general ledger report shows that some progress was made during the year clearing other balance sheet accounts. How- ever, several balance sheet accounts have the same beginning and ending balances, with no activity posted during the year. In addition, FCMAT observed some receivable accounts with credit balances and some pay- able accounts with debit balances. (The normal balance for receivables is a debit, and the normal balance for payables is a credit.) The consultants hired by the district to reconcile the balance sheet accounts proposed a restatement to the general fund, reducing the fund balance by $929,895. Fund balance restatements were also made to most of the other funds of the district. • Interviews with staff indicate that fund 76, the payroll warrant pass- through fund, has not been reconciled in several years. Regular reconcilia- tion of the fund would ensure that the payroll transactions and correspond- ing payments match and would ensure that all activity recorded in the fund is appropriate. The consultants hired by the district to reconcile the balance sheet accounts proposed a restatement to the fund totaling $793,585.56. • In the prior review period, the district provided a detailed time account- ing manual outlining regulations and providing instructions to employees on the forms to be completed. However, the manual was not provided to FCMAT for this review period, and FCMAT could not determine if it is still in use. This review period, the district provided a one-page summary of procedures, identifying the employee responsible for collecting the cer- tifications and the due dates of the forms. The district provided a sample of four time-certification forms completed during the 2019-20 fiscal year, but no time certifications that were completed during the current review period. FCMAT could not determine whether any time certifications were completed during the 2021-22 or 2022-23 fiscal years. Not com- pleting and collecting these documents timely for employees paid from federal funds can jeopardize current and future funding. 7. The district provided a Business Services Division Procedure Manual that it was in process of completing, which included some procedures for accounts payable, budgeting, position control, and purchasing functions. The manual contained a payroll section; however, no payroll procedures were included. Several staff members indicated that they were creating 294 Financial Management or updating desk manuals or procedures manuals. Some staff members reported that they do not have access or do not know where to find the procedure manuals that have been used in the past. Many fiscal services staff started in their positions only a year or two ago and additional training is needed, most notably in payroll, general ledger maintenance, and fixed asset tracking. 8. EC 41020(h) requires the following: Not later than December 15, a report of each local educational agency audit for the preceding fiscal year shall be filed with the county superintendent of schools of the county in which the local educational agency is located, the department, and the Controller. EC 41020.3 states, “By January 31 of each year, the governing body of each local educa- tional agency shall review, at a public meeting, the annual audit of the local educational agency for the prior year…” The district’s board meeting minutes indicate that the 2021-22 audit report was presented on January 11, 2023. The district complied with EC 41020(h) and 41020.3 for the 2021-22 audit. 9. External independent audit findings have continued to identify internal control deficien- cies as well as material weaknesses. Material weaknesses rise to a higher level of concern because they are significant deficiencies that result in a higher likelihood that the district’s internal controls will not prevent or detect a material misstatement of financial statements. Several findings relate to lack of internal controls, and some are repeated in each of the last several years audited. The number of audit findings increased from eight in 2020-21 to 17 in 2021-22. The district did not provide FCMAT with a corrective action plan for audit exceptions, and there is no active audit committee. The auditor issued a qualified opinion on the 2021-22 audit report because the district’s accounting records were inadequate and supporting documents were unavailable to support the amounts reported in the district’s financial statements for capital assets and depreciation. 10. Interviews did not identify an individual in the Purchasing, Accounts Payable, HR, or Pay- roll departments who was assigned to track and report STRS retiree payments per STRS Employer Directives 2022-01, 2022-03, and 2023-01 or PERS retiree hours per CalPERS Circular Letter Number 200-002-14 for retirees hired as consultants. HR receives monthly reports from LACOE that track the hours of retirees and non-CalPERS employees paid through payroll when they exceed 800 hours. The HR Department then contacts the su- pervisor of the employee to alert him/her that the employee is approaching 960 hours. No evidence was provided to indicate that the district tracks STRS retiree payments. 11. AB 5 was signed into law by the governor in September 2019 and became effective January 1, 2020. The law requires employers to apply a three-part test, known as the ABC test, to determine whether a worker qualifies to be classified as an independent contractor rather than an employee. Misclassification can result in substantial liabilities for employment taxes and penalties, which must be paid by the employer. Interviews did not identify an individual in the HR or Business Services departments who was responsible for making the determina- tion about whether a consultant qualified to be classified as an independent contractor. In a past review period, the district provided a workflow diagram of an independent contractor Financial Management 295 approval process; however, no documentation was provided to demonstrate that the process is used. FCMAT reviewed contracts, purchase orders, and payments made to several indi- viduals paid as independent contractors and found no written determination of independent contractor status in the documents provided. Recommendations for Recovery 1. The district should hire, train and cross-train sufficient qualified staff in the HR and Business Services departments motivated to implement the internal controls identified in this report as well as in the most recent audit findings. It should ensure that consultants hired by the district provide training to district staff to build internal capacity. 2. The district should meet with department managers monthly and continue to meet monthly with site managers and provide monthly budget reports to all managers responsible for site and department budgets. Business office staff should provide training on reading budget information in the financial system and on the proper coding of expenditures. 3. The district should continue to allow sites and departments to initiate budget transfers and should enter the transfers as soon as practical rather than waiting until the interim reporting period. 4. Journal entries and expenditure transfers should continue to include appropriate support documentation, be regularly completed, and be reviewed and approved by business office management. Field trip costs should be posted to site budgets in a timely manner. 5. Purchase requisitions should be reviewed for sufficient budget by account code, rather than by total site or department budget. 6. The district should consider configuring the position control system to encumber payroll once the installation of the new countywide financial software system is complete. The district should identify which documents drive the position control system, which positions are eliminated, and which are vacant in HRS, and eliminated positions should be regularly removed from the position control system. The procedure for the elimination of positions in the position control system should be documented. The total FTEs in the system should be reconciled monthly, and position control should be compared to actual payroll payments at least at each financial reporting period. 7. Procedures should be implemented at school sites to ensure that two people count cash together. 8. The district should continue to have sites review position control reports (both classified and certificated) with employee names, position title, FTE, and account codes, preferably during budget development and at each interim budget reporting period. After sites reconcile the reports, errors should be reported to the HR Department, and the department should update the database. 296 Financial Management 9. The district should ensure that it implements controls in the accounts payable system to check for duplicate invoice numbers for a given vendor rather than across all vendors to avoid duplicate payments. Accounts payable staff should continue to enter invoice numbers for each payment and consider discontinuing the time-consuming practice of tracking invoice payments manually for open purchase orders. 10. The district should ensure that the same individual, including those in the Purchasing Department, does not order, receive and approve the receipt of goods, including custodial and office supplies. 11. The district should continue to confirm the availability of sufficient cash balances before accounts payable batch processing. 12. All warrants should be returned to an identified Business Services Department or Food Services Department staff person other than the employee who processed the transaction. 13. Prior year accounts payable and accounts receivable balances should be reconciled by October 31 following the close of the fiscal year. Outstanding items should be researched and cleared in a timely manner. Any amount written off in the annual reconciliation process should be reviewed and approved by management staff. 14. Controls should be implemented to ensure that revenues and expenses accrued as part of the prior year closing are not also entered as current year revenues and expenses, thus overstating current year revenues and expense costs. 15. The business office should maintain logs and reconciliations to support all balance sheet items in all funds, including accounts payable, accounts receivable, cash on deposit with fiscal agent, revolving/petty cash and inventory. The district should reconcile fund 76, the payroll warrant pass-through fund, and all payroll clearing accounts monthly. 16. The district should follow reporting guidelines for timely federal time reporting for all employees who are paid from federally funded programs in compliance with Title 2, Code of Federal Regulations (2 CFR), Part 200. 17. A desk manual should be developed for each position in the Business Services Department, and the district should ensure that each employee includes in his or her desk manual step-by-step procedures for assigned duties. 18. The district should continue to work with its independent auditors to ensure that their work can be completed in time to comply with the December 15 and January 31 deadlines required by EC 41020(h) and 41020.3. 19. Policies, procedures and internal control measures should be reviewed and revised to address audit findings. Procedures should be established to avoid repeating the same audit finding in future years. Financial Management 297 20. The district should determine who is responsible for PERS and STRS reporting of retiree vendors/consultants, provide that person with appropriate training, and require service vendors/consultants to complete a form that properly identifies PERS and STRS retiree status. 21. The district should implement a process and assign responsibility for making the determination about whether a consultant should be classified as an employee or as an independent contractor. The results should be documented, and a copy should be kept with the contract/purchase order backup documents. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 298 Financial Management 10.5 Accounting, Purchasing, and Warehousing Professional Standard The LEA has adequate purchasing and warehousing procedures to ensure that: (1) only properly authorized purchases are made, (2) authorized purchases are made consistent with LEA policies and management direction, (3) inventories are safeguarded, and (4) purchases and inventories are timely and accurately recorded. Findings 1. The district implemented the BEST financial system in July 2022 and uses the online purchase requisition system. Users were required to complete training with the county office before receiving login credentials. The business office offers training as needed, and staff indicated that their questions are answered as they arise. It would benefit the district to provide an annual in-service before the start of school, including training in the online requisition system and account coding. Training in proper coding of expenditures and handouts of the training materials should be provided to office managers and administrative secretaries who cannot attend the training. Several staff members reported that they need additional training in the BEST system and proper coding of expenditures. 2. Staff reported that purchase orders are required for all purchases. FCMAT confirmed this based on a sample review of accounts payable documents. The purchasing process and travel reimbursement process are as follows: • District procedures require approval of purchases at the district administrative level and any exceptions to the procurement procedures must be approved by administration. Sites/departments are not allowed to enter into contracts, and all contracts require district administrator and county administrator/board approval. • The originating site or department completes an online purchase requisition for the authorized manager to approve, and the document is routed electronically to the business office for processing. Interviews indicated that the initiator of the requisition should request a quote and attach the quote to the requisition. If a quote is not attached, the purchasing staff will obtain a quote. • The Business Services Department checks the account coding and determines whether the total site/department budget has funds for the purchase. Interviews indicated that purchase requisitions with insufficient funds in the designated account may be approved if other site/department accounts have sufficient budget to cover the purchase. • Sites and departments can initiate budget transfers electronically using the budget transfer form in Informed K12. Budget transfer requests are not usually processed right away but are held and processed during interim reporting periods. Financial Management 299 • Requisitions are routed electronically to the Purchasing Department after appropriate approvals, where they are processed into a purchase order. • The Purchasing Department is responsible for determining whether IRS Form W-9 is required for independent contractor reporting and whether the purchase is subject to bid requirements. Purchasing establishes and can make changes to vendors in the system. • Purchase orders are issued to vendors with copies forwarded to the requestor and the Accounts Payable Department. When technology equipment is purchased, a copy is transmitted electronically to the IT Department to check for compatibility. If a contract is involved, the Business Services Department is responsible for ensuring that it is signed and has county administrator/board approval before the purchase is made. • Each week, the purchasing assistant reviews requisitions in the purchase order summary report that are not moving through the system, pending approval. The purchasing assistant indicated she sends two reminders to the approver via email before cancelling the unapproved requisition. • The proof of delivery/packing slip for merchandise is sent directly to accounts payable. Instead of a signed packing slip, accounts payable may accept a signed copy of the purchase order or invoice as proof of receipt. • Requests for conference and travel are completed online using the Travel & Conference/Workshop Pre-Authorization form. Departments/ sites are instructed to complete the preauthorization form, secure the supervisor’s approval, and send it to the business office. Board policy requires board approval in advance for out-of-state travel, and district procedures require board approval in advance for conference expenses of more than $500. The Business Services Department administrative assistant puts conference requests for out-of-state travel and expenses of more than $500 on the board agenda for approval. After the event, the reimbursement forms, with all supporting documentation attached, are sent to the Business Services Department. 3. The district is working on updating/completing a purchasing manual. In addition, the district’s Business Services Division Procedure Manual includes a Purchasing Department section. The procedures in each of these two documents sometimes conflict. The district’s written procedures do not include all responsibilities for implementing procurement procedures. Following are some of the written procurement procedures: • The Business Services Division Procedure Manual indicates: …all purchases in excess of $96,700.00 (Effective January 1, 2021-subject to increase annually) for services, an item or group of items, shall be made by first securing formal competitive bids. However, the District utilizes a [sic] $10,000.00 as the threshold to ensure that we stay below the bid requirement. 300 Financial Management However, Public Contract Code (PCC) Sections 20111 and 22002(c) include some bid thresholds that are lower than $96,700. In addition, EC 39802 includes a $10,000 threshold for transportation contracts and states as follows: In order to procure the service at the lowest possible figure consistent with proper and satisfactory service, the governing board shall, whenever an expenditure of more than ten thousand dollars ($10,000) is involved, secure bids pursuant to Sections 20111 and 20112 of the Public Contract Code whenever it is contemplated that a contract may be made with a person or corporation other than a common carrier or a municipally owned transit system or a parent or guardian of the pupils to be transported. The governing board may let the contract for the service to other than the lowest bidder. The current bid threshold is $109,300 effective January 1, 2023. The information in the draft Purchasing Department SOP is insufficient to explain how to bid within PCC and EC requirements. • The district adopted the California Uniform Public Construction Cost Accounting Act (CUPCCAA), PCC 22000, et. seq., regulations at its June 27, 2014 board meeting. The purchasing section of the district’s Business Services Division Procedure Manual includes minimal CUPCCAA information and includes the current bid thresholds. The draft Purchasing Department SOP includes information about bidding requirements for public works projects that are valued at more than $200,000 but makes no reference to CUPCCAA. In 2017, the district provided FCMAT a CUPCCAA Quick Reference Sheet for public works and maintenance projects. This document had various procedures for project awards up to $187,500 given different conditions based on project costs. It stated it is not applicable for equipment or nonconstruction type services. FCMAT was not provided with an updated CUPCCAA Quick Reference Sheet with updated amounts for the current review period. • The district contracts with PQBids to manage and maintain the list of qualified contractors and required notifications. During this review period, the district provided FCMAT with its CUPCCAA vendor list. The district has continued to publish bid results in the award of contracts on board agendas, improving bid transparency. • The Business Services Department is responsible for advertising for bids, placing bid information on the district’s website, and placing contracts on the board agendas. The draft Purchasing Department SOP states that the Purchasing Department may obtain additional quotes for purchases that already have a quote attached to the requisition and will get multiple quotes on products or services if they exceed $500. Financial Management 301 However, the samples of accounts payable transactions reviewed included no evidence that quotes were requested or obtained. During the current review period, the district purchased items such as furniture, technology equipment, and cafeteria equipment and no evidence of multiple quotes or bids was attached to the purchasing/accounts payable backup docu- mentation or published on the board agenda. 4. The Maintenance, Operations and Transportation Department is responsible for complying with reporting requirements related to the Department of Industrial Relations (DIR) contractor registration program, which began in March 2015. All public works projects having accumulated more than $1,000 in expenses paid for by a school district, regardless of the funding source, are subject to prevailing wage rates and DIR registration and reporting requirements under SB 854. DIR registration and reporting are not required for contractors who qualify for the small project exemption, which applies to public works projects that do not exceed $25,000 and maintenance projects of less than $15,000. The contracts state and purchase orders include a link to the requirements for labor costs procured by the district, including those for the Food Services and Maintenance, Operations and Transportation departments. The district has contracted with PQBids to implement DIR registration requirements and develop prequalified applications. DIR certifications were not attached to any of the sample vendor contracts viewed by FCMAT. 5. Authorization to participate in a piggyback bid for “Just in Time” procurement of classroom and office supplies was approved at the June 30, 2021 board meeting and authorization to continue to participate for the 2022-23 fiscal year was approved on June 29, 2022. This flexibility requires more communication regarding segregation of duties, tagging procedures, and responsibility to safeguard purchases. Some site personnel were reportedly handling all functions of the transactions: ordering goods, receiving goods, and storing goods. 6. Vendors and/or issuing departments are responsible for tracking an approved signer on an open purchase order. If a list of approved signers is provided on the original purchase order, interviews with accounts payable staff indicated that they do not verify that the person who received the goods was an approved signer. FCMAT selected a sample of eight open purchase orders for review. Each of the open purchase orders reviewed listed approved signers. However, the district did not provide any invoices paid against the open purchase orders selected, so FCMAT could not determine whether the person signing for the goods was listed on the purchase order. The purchasing assistant indicated that the approved signer list on file with vendors is verified annually. 7. FCMAT’s interviews found that accounts payable personnel check for proper remittance addresses and refer all new vendors and vendor address changes to the Purchasing Department to ensure proper segregation of duties. 8. Purchase orders, invoices and receiver documents are matched and processed for payment in the financial system. Accounts payable staff reconcile the items, quantities, and prices on the invoices with the purchase order and receiving document. These items are placed in a folder and delivered to the senior executive director of fiscal services. The 302 Financial Management senior executive director of fiscal services ensures the packets are complete to support the warrants, compares the warrants in the system to the documentation provided for accuracy, and reviews them for reasonableness. The approval in the financial system triggers the daily process of issuing warrants at the county office. Normal processing time for the county office is approximately four days; however, this period may be extended if that office places an audit hold on the batch. The county office issues warrants with one signature attached, and the documents are deliv- ered to the Business Services Department. When commercial warrants are delivered from the county office to accounts payable staff, the staff matches the warrants to invoices and the payment packet, and the CBO signs the warrants as the second signatory. The invoices are stamped as “processed” with the date. Accounts payable staff indicated that they each prepare their own warrants for mailing. The same person who prepared the batch has custody of the warrants once they have been issued by the county office; however, proper segregation of duties would require these two functions be separated. 9. BP 3350-Travel Expenses (revised February 20, 2019) describes the approval and reimbursement processes for travel and conference expenses. District procedures limit the meal allowance to $50 per day for full-day conferences. The district’s Travel & Conference/ Workshop Pre-Authorization form specifies maximums of $10 for breakfast, $15 for lunch and $25 for dinner. Detailed receipts are required for reimbursement of conference and travel expenses, and the form indicates that if meals are included with a conference, employees do not qualify for those meal payments. A best practice is to establish specific travel times to qualify for breakfast and dinner. For example, a traveler must have a departure time of before 6:30 a.m. to qualify for the breakfast per-diem payment and a return time of after 6:30 p.m. to qualify for a dinner. Over the past few years, the IRS has placed additional scrutiny on meal reimbursements or payment of per diems on travel that does not warrant an overnight stay (Internal Revenue Code Section 162(a)(2) Revenue Ruling 75-170). In IRS audits of a county office of edu- cation in California, meals that were not associated with overnight stays were deemed to be “living expense and thus a taxable fringe benefit.” If the district includes nonovernight travel in its meal reimbursement policies, it may need to report the payments as taxable income to the employee. Problems often arise in travel and conference when requests and reimbursements are not processed in a timely manner. In interviews, staff indicated that conference requests for more than $500 and out-of-state travel need county administrator/board approval prior to the conference. However, interviews with staff and a review of board meeting minutes confirm that travel and conference requests are sometimes not preapproved. Approximate- ly 24% of the requests for more than $500 or out-of-state travel listed on the board agen- das from February 2022 through January 2023 were not preapproved, including several for administrators. District procedures state that travel expense reimbursement claims must be submitted within 10 working days following return from travel and claims not submitted within 30 Financial Management 303 days of travel may be subject to denial. However, staff reported that employees often turn in travel claims more than 30 days after the conference. The 2021-22 audit report con- tained a finding that one employee turned in a mileage claim form more than one year after the travel occurred. District employees who travel on school business are considered eligible for state govern- ment rates and a waiver of hotel taxes. These items seem minor, but can add up when several people travel, or a single person takes multiple trips. District policy does not specify how an employee qualifies for an overnight stay. This is of particular concern when a conference is within the local geographical area and lasts several days. EC 44032 requires districts to pay for “actual and necessary” expenses. The expense would be actual for this type of conference because the person stayed in the hotel but may not be necessary given the geographical location. The district’s board policy states that employees traveling on school business are expected to travel by the most economical means, and that if two or more persons share automobile transportation, only one is entitled to mileage reimbursement. 10. Interviews with staff indicate that the district has issued credit cards to four administrators. These cards are regular business credit cards, allowing all purchases with limits from $5,000 to $20,000. The district has no written policy or procedure for cancelling a credit card if a cardholder leaves the employment of the district. The district does not require all individuals using district credit cards to read and sign a credit card user agreement acknowledging receipt of the card, terms of use and reimbursement procedures. 11. FCMAT requested samples of the district’s accounts payable transactions for testing the fiscal years 2021-22 and 2022-23. Of the 25 payments selected, backup documentation was provided for only 10 items, and the following anomalies were noted: • Of the 10 invoices provided, seven were paid more than 30 days after the invoice date and three of the seven were paid more than 90 days after that date. Seven of 10 invoices provided were dated prior to the date of the purchase order. • Four of the 10 invoices were paid for consultant services that were per- formed prior to the date of the purchase order. Documentation was not included with the consultant services agreements to indicate that the district applied the three-part (ABC) test to determine if the consultants should be properly classified as independent contractors. There was no documentation to support whether the district inquired about the con- sultant’s status as a retiree of STRS or PERS for reporting purposes. • Two of the 10 invoices were for supplies or services provided in the prior fiscal year. • One contract was signed by a department director, although district pro- cedures require district administrator approval. 304 Financial Management • No backup was provided to FCMAT for the sample of open purchase orders selected for testing, so FCMAT could not determine if purchase or- ders were created prior to the invoice date, whether quotes were obtained, whether proof of delivery was obtained, or whether the person signing for the goods was an authorized signer listed on the purchase order. 12. AR 3440 (revised February 20, 2019), Inventories, complies with the EC 35168 requirement that the governing board establish and maintain an inventory of all equipment items with a current market value of more than $500. GASB Statement No. 34 requires fixed asset records to be maintained in a complete, accurate and detailed manner and specifies that fixed asset records include acquisition date, historical cost, depreciation and useful life of the asset. Capital assets are to be reported at historical cost and are defined as land, improvements to land, easements, buildings, building improvements, vehicles, machinery, equipment, works of art and historical treasures, infrastructure, and all other tangible and intangible assets that are used in operations and that have initial useful lives extending beyond a single reporting period. When federal funds are used for a purchase, the district is required to include additional information in its inventory records, including the funding source, titleholder, and percent of federal participation (2 CFR 200.313 and 5 CCR 3946). At least once every two years, a physical inventory of equipment must be conducted, and the results reconciled with the property records (2 CFR 200.313). On February 17, 2021, the district awarded a contract to CBIZ Valuation Group to perform a capital asset inventory and valuation, barcode tagging, and reconciliation to the district’s existing fixed asset list. Interviews and documentation support that a physical inventory, bar coding and asset tagging took place. However, there is no evidence that an exception report was produced (see Standard 16.1 for additional details). Interviews with employees indicated that fixed asset items that were not related to technology and were purchased or donated after completion of the physical inventory have likely not received asset tags. No documentation was provided that accounts for current year inventory additions or items on prior inventory lists that were removed because of disposals, shrinkage or theft. As is discussed in more detail in Standard 15.8 and 16.1, the district’s inventory has not been maintained in a dedicated inventory system, and gaps in the district’s internal controls can allow items to be received, but not tagged or included in the equipment inventory. Disposals, shrinkage and/or theft of items valued at less than $5,000 has not been systematically tracked, and the items have not been removed from the fixed asset inventory list. This may perpetuate the misstatement of assets in the financial reports. 13. Several years ago, the district eliminated a large central warehouse and began to use a small warehouse adjacent to the maintenance yard and allowed district office and site staff to receive supplies and technology items directly. Most items are shipped directly to the sites and departments. The inventory and distribution coordinator position will be responsible for managing the inventory database and updating and tracking district inventory; however, the individual in the position has not yet been trained in those duties. Financial Management 305 Recommendations for Recovery 1. The district should provide employees who use the online requisition system with an annual in-service that focuses on how to use the purchasing module and the proper account coding of requisitions and should consider making the training mandatory. Training materials and step-by-step instructions should be provided to office managers, administrative secretaries, and others responsible for the input of requisitions. 2. The review of approved signers on open purchase orders is a district office function that should be assigned to district office staff. Approved signers should be determined by the department requesting the open purchase order, and the names should continue to be printed on the open purchase order. This information allows the accounts payable staff to identify approved signers. 3. The business office should continue to audit all invoices. 4. The Business Services Department should make budget transfers initiated by departments and sites in a timely manner. Purchases and new positions submitted for approval should be rejected until sufficient funds are transferred to cover the purchase or pay for the position. 5. The district should enforce its policy requiring an approved purchase order for all purchases and hold employees accountable for following the policy. All vendors should be notified in writing that invoices received without a valid purchase order number, listed on the invoice, will be returned without further processing. 6. In accordance with district procedures, it should not allow department directors to sign contracts. 7. The district’s purchasing procedures and the draft Purchasing Department SOP should be completed and reviewed and revised annually. The documents should contain consistent information. Board policies and administrative regulations on procurement and bidding should be adopted and/or revised as necessary. 8. To identify cumulative purchases that must be bid, the Purchasing Department should complete all capital purchases that are not bid as part of new construction projects. 9. The Purchasing Department should obtain quotes as prescribed in the district’s purchasing procedures and attach a copy to the accounts payable file as supporting documentation. 10. The district should ensure that it has sufficient qualified staff in the Purchasing Department who are trained in procurement practices and requirements. 11. The district should ensure that it has completed all the required steps to implement CUPCCAA and provide training regarding this procurement process to applicable staff members. Staff members involved in purchasing should have access to district procedures as well as PCC training. 306 Financial Management 12. Purchase orders for labor of more than $15,000, not covered by CUPCCAA, should be bid where required by the PCC. 13. To adequately segregate duties, the district should continue to ensure that only the Purchasing Department can establish a new vendor or make changes to vendor information. Purchasing staff should not receive items or approve invoices for payment. 14. Packing slips should be attached to invoices as the preferred proof of receipt. The Purchasing Department should receive packing slips, follow up on any missing or damaged items, then forward the packing slips to Accounts Payable. 15. The district should continue to ensure that cash balances have been reviewed and any concerns have been addressed before an accounts payable batch is processed. When the district’s processing time to produce a warrant has been diminished, the district should consider issuing warrants less than daily. 16. All accounts payable warrants should be returned to personnel other than the employee who processed the transaction. 17. Care should be exercised in reviewing accounts payable packets before authorizing issuance of payment. Contracts should be attached to the backup documents. 18. The district should revise its travel and conference board policies and administrative regulations to include items such as specific times for breakfast and dinner per diems, use of state government rates, qualifications for an overnight stay, and requirement for overnight stay to qualify for meal per diem. The district should also consider using a waiver for hotel taxes. It should hold employees accountable for following the travel expense reimbursement procedure that requires employees to submit claims for reimbursement within 10 working days following return from travel. 19. The district should require managers who have access to credit cards to read and sign a credit card user agreement acknowledging receipt of the card, terms of use and reimbursement procedures. The district should develop and implement a procedure to ensure that credit cards are cancelled when a cardholder leaves the employment of the district. 20. The district should ensure that it complies with the DIR contractor registration requirements and attach the DIR certification to purchase order backup. 21. Additional procedures and internal controls, such as segregation of duties, should be implemented for “just in time” office supply and custodial procurement contracts. 22. The district should ensure that the same individual is not assigned to approve purchase orders and warrants online. 23. Invoices should be paid in a timely manner, and district employees should obtain timely approval for travel that requires county administrator/board approval. Financial Management 307 24. The district should apply the three-part (ABC) test to consultants to ensure that they are properly classified as independent contractors or employees and require consultants to complete a form identifying their status as retirees of STRS or PERS for proper tracking and reporting. 25. The district should ensure that supervisors adhere to policies prohibiting the purchase of items valued at more than $500 on an open purchase order. 26. The district should centralize all purchasing, bidding, tagging and salvage procedures. This would ensure that one individual or department is responsible for all items districtwide. This would centralize knowledge, standardize procedures and increase accountability. 27. The district should perform a physical inventory of all items with a current market value of $500 or more every two years to conform to EC 35168 and 2 CFR 200.313. The district should consider an annual physical inventory until all items are tagged, and all procedures are fully implemented. All purchases and donations that fall into reportable categories should be accounted for. 28. The district should assign the roles and responsibilities to employees to maintain an inventory control system. Employees responsible for identification of applicable assets and those responsible for asset tagging should be cross-trained on their responsibilities. 29. The district should ensure that the inventory is continually updated for additions and deletions. 30. The inventory list should be annually reconciled to the accounting records of items purchased using object codes 4400, 6400, and 6500. 308 Financial Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 0 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 1 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 309 11.1 Student Body Funds Legal Standard The board adopts board policies, regulations and procedures to establish parameters on how stu- dent body organizations will be established, and how they will be operated, audited and managed. These policies and regulations are clearly developed and written to ensure compliance regarding how student body organizations deposit, invest, spend, and raise funds. (EC 48930-48938) Findings 1. The district adopted BP 3452-Student Activity Funds, at its February 20, 2019 board meeting. Board policies and administrative regulations and procedures governing associated student body should be communicated with the appropriate staff to ensure they are fully implemented at all school sites operating ASBs. 2. The district does not provide adequate guidance or procedures that outline how associated student body organizations are to operate including district-level oversight even though it has historically requested outside agencies to perform fraud audits of the ASB. The district is required to provide proper supervision of ASB in accordance with EC 48937, which states the following: The governing board of any school district shall provide for the supervision of all funds raised by any student body or student organization using the name of the school. During the prior review period, the new director of fiscal services had recently been as- signed to oversee the ASBs; this individual resigned in October 2022. At the time of FC- MAT’s fieldwork, the newly appointed interim director of fiscal services had not yet been assigned ASB oversight. 3. BP 3452 states the following: The Superintendent or designee shall develop internal control procedures to safeguard the organization's assets, promote the success of fund-raising ventures, provide reliable financial information, and reduce the risk of fraud and abuse. These procedures shall detail the oversight of activities and funds including, but not limited to, the appropriate role and provision of training for staff and students, parameters for events on campus, appropriate and prohibited uses of funds, and accounting and record-keeping processes, including procedures for handling questionable expenditures. 4. Some of the district’s ASB organizations use the downloadable copy of FCMAT’s Associated Student Body Accounting Manual, Fraud Prevention Guide and Desk Reference. The district provided FCMAT with an ASB Financial Guide Inglewood Unified School District (For Schoolsite Use), which contains various procedures and forms for the ASB budget, cash receipts, fundraising activities, events, sales, and expenditures. However, the document is undated, incomplete, and was not mentioned by staff during interviews. 310 Financial Management The district has not yet implemented previous recommendations to provide written internal guidelines and procedures for ASB that provide direction to ASB personnel, ensure effective administrative oversight, and clearly define the roles and responsibilities of all personnel involved in managing student body activities and funds. 5. The district has centralized the TK-8 and middle schools’ ASB deposit and payment functions at the district office, and staff indicated funds are deposited in the clearing account and transferred to fund 08, and the district’s accounts payable system is used to process ASB payments. 6. During the prior review period, the district began implementing the ASBWorks accounting software at its high schools, with access for business office staff to view financial transactions. However, the high schools continue to use various software programs to track ASB financial transactions such as deposits and check register and club account balances; one uses ASBWorks, but the other has not yet transitioned to this software program. As mentioned in previous review periods, the district should use uniform financial software to prepare the school sites’ monthly financial documentation that can also be accessed by the Business Services Department. 7. High school ASB staff indicated that the business office requests copies of bank reconciliations monthly and occasionally requests copies of ASB meeting minutes. The district provided FCMAT a written document that states monthly reconciliations are collected from the high schools and that backup documents are requested; however, the document does not indicate what the business office does with the documents and if staff reviews them. To provide adequate district-level oversight, the district should assign a business office staff member to routinely collect and review ASB financial reports, including bank reconciliations, and perform random sampling of revenue and expenditure transactions. 8. At the two sites FCMAT selected for review, interviews with middle school staff indicated that the teacher overseeing ASB left, and the site is not operating an ASB during the current school year; it is unknown when the ASB will be reinstated. Interviews with high school staff indicated that electronic payment systems are used to collect funds for athletic events and student store sales, and that cash can also be used to purchase items from the student store. The ASB clerk collects the cash from the sale of student store items and counts the money with the assistant principal. The ASB clerk and assistant principal both sign a cash count form, and money is kept in the safe until the ASB clerk takes the deposit to the bank. The ASB clerk completes the bank reconciliation, but it is not reviewed by another site employee. Effective internal control procedures and best practices require that an employee counts all cash in the presence of another employee and that a deposit slip is completed and signed by both individuals. A different employee should then be assigned to verify that the total shown on the deposit slip matches the amount deposited at the bank and to review the bank reconciliation. 9. EC 48933(b) requires that all ASB expenses be approved before funds are expended. Interviews with staff indicated that ASB expenses are preapproved and that meeting minutes are attached to purchase orders. The ASB Check Request Voucher for TK-8 and middle schools and the Check Request Form and Purchase Order Form (provided during Financial Management 311 the prior review) used by the high school site that FCMAT selected for review include signature lines for the three required approvers. In addition, the high school’s forms include a statement certifying that the request has been approved by the ASB and a line to enter the date of the respective ASB meeting. 10. FCMAT has found that the schools operating an ASB program have created various forms for revenue collection and some expenditure documents along with various formats for taking meeting minutes. During the prior review period, the district developed a few standardized ASB procedures and forms for its TK-8 and middle schools (e.g., ASB Check Request Voucher and Deposit Slip). 11. In a prior review period, interviews with staff indicated that students were required to purchase PE uniforms from the student store. Students who could not afford to purchase the uniforms were referred to the parent center at the district office to obtain a voucher to receive a free uniform. The California attorney general has issued an opinion that indicates charging for standardized gym clothes for physical education classes, or uniforms, is not allowed. A student’s grade cannot be adversely affected by not wearing the standardized clothes when the failure to wear these clothes is beyond the student’s control. Interviews also indicated that schools sold caps and gowns for eighth-grade graduation ceremonies. EC 49011 states that pupils shall not be required to pay a fee for participation in an educational activity. During last year’s review, ASB staff reported that the ASB no longer sold PE uniforms or caps and gowns. However, during the current review period, staff indicated that the district has directed ASBs to sell caps and gowns for graduation ceremonies. Recommendations for Recovery 1. The district should share BP 3452 with school site administrators, student body advisors, and staff performing bookkeeping roles at the school sites, as well as district office personnel who are assigned to oversee ASB activities. 2. The district should ensure that all staff responsible for ASB bookkeeping have the knowledge, skills, and training necessary for those duties. 3. The district should implement procedures on how ASBs should deposit, invest, spend, and raise funds and ensure adequate internal controls are established following procedures outlined in the FCMAT ASB manual. 4. The district should complete development of the ASB Financial Guide Inglewood Unified School District (For Schoolsite Use) and implement it. The district should ensure the manual includes written internal ASB procedures that provide direction to staff, ensure effective site administrative oversight, clearly define the roles and responsibilities of personnel involved in managing student body activities and funds, and that it includes standardized forms for fundraising, cash collection, disbursement of funds, and recording meeting minutes to be used by all school sites operating an ASB. 5. The district should develop and implement procedures for adequate district-level oversight of student body funds and internal audits by assigning a business office 312 Financial Management staff member to routinely collect and review ASB financial reports, including bank reconciliations, and perform random sampling of transactions. The district should hold sites accountable for providing the requested information. 6. The district should continue to implement the ASBWorks software and provide staff training to streamline ASB accounting. The district should also continue to ensure that district office staff have access to view financial information in the software system. 7. The district should ensure that duties are properly segregated for ASB bank accounts and check writing duties that have been centralized at the district office. 8. The district should ensure that effective internal control procedures are implemented inclusive of requiring two employees to count cash together and complete and sign the deposit slip, assigning another employee to verify that the total shown on the deposit slip matches the amount deposited at the bank and to review the bank reconciliation. 9. The district should ensure that all ASB expenses are approved in accordance with EC 48933(b) before funds are expended. It should also ensure that standardized purchase and check request forms include the ASB meeting date when the purchase was approved and signatures for all required approvers. 10. The district should ensure that students are not charged any unallowable fees. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 0 July 2018 Rating: 0 July 2019 Rating: 1 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 313 11.3 Student Body Funds Legal Standard The LEA provides annual training and ongoing guidance to site and LEA personnel on the poli- cies and procedures governing Associated Student Body accounts. Internal controls are part of the training and guidance, ensuring that any findings in the internal audits or independent annual audits are discussed and addressed so they do not recur. Findings 1. The Business Services Department is responsible for ASB oversight, internal audit, and training, but does not have written protocols, processes, or procedures for these functions. Oversight procedures are necessary to provide direction to ASB staff and ensure effective administrative oversight and should clearly define the roles and responsibilities of person- nel involved in managing student body funds and activities. FCMAT has cited the lack of ASB oversight in several previous reviews, and the 2021-22 annual audit continues to include a finding regarding the lack of internal controls and oversight of ASB funds. However, as discussed in Standard 11.1, the business office has not provided adequate oversight of the ASB organizations, which violates EC 48937. During this review period, the director of fiscal services who had recently been assigned to over- see the ASBs resigned, and the newly appointed interim director of fiscal services had not yet been assigned ASB oversight. 2. As mentioned above, the district’s annual audited financial statements continue to include a reoccurring ASB audit finding. The most recent audit completed by the external audi- tor for the fiscal year ended June 30, 2022 included Finding 2022-003–Associated Student Body (ASB) Funds. The audit identified the finding as a material weakness and stated the following: … there was no review process of ASB accounting […] Due to this lack of oversight, the District is unable to determine if all ASB accounts have been properly reported. There is a risk that ASB accounts could be misstated and that this misstatement would go undetected by the District Office. The audit indicated that the lack of internal controls and oversight by the district office could lead to loss or misappropriation of ASB assets and carries a risk that student body funds may not be used for the students’ benefit. Repeat audit findings should be of great concern to district administrators. Although interviews indicated that the 2021-22 au- dit findings have been shared with principals, the findings have not been provided to all school site ASB staff. 3. Periodic internal audits provide an opportunity for ASB bookkeepers to be trained on proper procedures and to correct deficiencies that can lead to audit findings. FCMAT found that the district does not conduct periodic internal audits of ASB programs to test and ensure compliance. 314 Financial Management 4. The district has not established written procedures to ensure that ASBs collect all W-9 forms and provide the district with payment information, so it can issue 1099s as re- quired by IRS regulations. The entire independent contractor process should be central- ized through the district office, and training should be provided to the school sites that includes procedures for schools that have ASBs to send W-9 forms to the district office. During this review period, staff indicated that original W-9 forms are kept at the school site and a copy is sent electronically to the business office; however, some vendors have not provided a W-9. 5. During this review period, the district provided ASB training on September 28, 2022; the meeting sign-in sheet shows that eight site staff members attended. The training was conducted by the district’s external audit firm and included information about rules and regulations, budget controls, cash receipts, cash disbursements, accounting and audit, and fraud prevention. Some staff members are relatively new to their ASB roles, and ASB staff indicated that they need additional and/or annual training. Recommendations for Recovery 1. Written oversight procedures should be established to provide direction, ensure effective oversight, and define the roles and responsibilities of personnel involved in managing student body activities and funds. 2. The district should provide training for district-level personnel to conduct internal audits of ASB funds, and the business office should conduct periodic internal audits of ASB funds to test for and ensure compliance. 3. The district should ensure that proper oversight is conducted at the district office level and that audit findings are reviewed with applicable school site staff and site administrators to ensure corrective action and avoid repeat audit findings. 4. The independent contractor process should be centralized, and procedures should be implemented to ensure ASBs collect W-9s and send the forms and vendor payment information to the district’s business office staff so the district can issue 1099s as required by IRS regulations. 5. The district should provide training, for both new employees and annually, that include topics such as processes and procedures, internal controls and review of audit findings for all employees who are responsible for ASB funds. The district should make this training mandatory for all applicable employees and administrators and ensure that attendance rosters are completed for all trainings. Financial Management 315 Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 0 July 2018 Rating: 1 July 2019 Rating: 1 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 1 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 316 Financial Management 12.1 Multiyear Financial Projections Legal Standard The LEA provides a multiyear financial projection for at least the general fund at a minimum, consistent with the policy of the county office. Projections are done for the general fund at the time of budget adoption and all interim reports. Projected fund balance reserves are disclosed and assumptions used in developing multiyear projections that are based on the most accurate information available. The assumptions for revenues and expenditures are reasonable and sup- ported by documentation. (EC 42131) Findings 1. The district’s reports for the following periods all included MYFPs for the general fund in accordance with AB 1200 and AB 2756 requirements for the current and subsequent two fiscal years. • 2021-22 second interim report • 2022-23 adopted budget • 2022-23 first interim report 2. Board presentations for the current year and multiyear financial projections should include a description of budget assumptions used in the MYFP and illustrate the financial impact of those assumptions, such as changes in revenues, expenditures and fund balance. Addition- ally, the district should provide a summary table of the multiyear financial projections that reflects the district’s financial position. This is an effective practice to help those affected more easily understand the district’s fiscal position. FCMAT found that the district has included a MYFP table as part of its board presentations that illustrates the year-over-year change in the current and multiyear financial projections. However, the board presentation does not include the detailed assumptions used to create the subsequent fiscal years. All board presentations given during the review period included a slide for MYFP and the dol- lar amount of reserves, but the slides did not separate the unrestricted and restricted general fund impacts and did not include the available reserve percentage. 3. FCMAT’s review of the district’s board agendas shows that detailed assumptions were provided in the board agenda backup materials for both the 2021-22 second interim and 2022-23 adopted budget. Although FCMAT was provided documentation of the 2022-23 first interim assumptions, a review of the December 14, 2022 board agenda does not show it was provided as supporting backup material. Additionally, the district is still not consis- tent with the extent of details provided with each of the required budget submissions. The assumption narratives included the FSP, and some of the supporting assumptions provid- ed information in the following areas: • Student enrollment trends • Projected enrollment • Step and/or column increases Financial Management 317 • Increases in CalSTRS and CalPERS • Health insurance increases • Use of one-time revenues • Deficit spending and reserves • Special education costs However, assumption narratives for some periods are lacking detail in the following areas: • Unduplicated pupil count • Average daily attendance rate (ADA) • Staffing reductions from declining enrollment that correlate to the amounts projected in the district’s FSP and MYFP • The district’s increases/decreases in contributions to restricted programs • Correlation of increased or improved services to students resulting from additional or carryover of supplemental and concentration grant funding identified in the district’s LCAP • A summary table of the multiyear financial projections for unrestricted and restricted sources that reflect the district’s financial position, including the available reserve percentage The district’s assumption narratives have not consistently included the cohort survival factors with the enrollment projections or unduplicated pupil count (UPC), and average daily attendance projections are still not included. Accurate projections of enrollment, UPC and ADA are essential elements of the MYFP, they are all core components of the LCFF calculation and are vital in identifying changes that may affect the district’s revenue in the current and subsequent years of a projection. The assumptions provided to board members and with the board agenda backup materials Include more of the factors used than what was provided with some of the past budget submissions but the focus remains on the current year and no detailed document that describes all the assumptions used to develop each year of the district’s general fund MYFP is presented. The district’s assumptions narrative included a table of some rate assumptions; however, it did not include the multiyear impact on the district’s financial position. A best practice is to include a summary list of all assumptions used to develop the district’s budget and MYFP in the narrative document. 4. The MYFP is a key tool in assessing the district’s ongoing fiscal sustainability by taking the base year budget and projecting the future years with locally known assumptions and trends. If the base year is underbudgeted or overbudgeted, the reliability of the projections for the two subsequent fiscal years is affected and may not reflect an accurate picture of the district’s financial status. 318 Financial Management 5. The district develops its MYFP using the SACS software along with Excel spreadsheets for supporting information. The district had implemented FCMAT’s recommendation to prepare its budgets at each resource level during the prior review period. However, no documentation was provided for FCMAT to verify that any of the financial reports for this review period were prepared at each resource level. With all the additional one-time funding that the district is receiving, it is imperative that the district track the expenditures and monitor ending balances to ensure that each program does not deficit spend and require a contribution from the unrestricted general fund. Additionally, the district should ensure that one-time funds are not used for ongoing costs. Developing MYFPs at each resource level can provide a greater level of detail and accuracy and better financial planning. 6. In 2018, AB 1840 added EC 42161 to aid in the district’s fiscal recovery. The provisions of AB 1840 expired in fiscal year 2021-22; however, the Budget Act of 2022 provided additional relief under AB 181 Section 37, which established EC 42163. EC Section 42163 provides for an annual appropriation for the district of up to 25 percent of the district’s projected operating deficit if the district complies with specified terms, beginning with the 2022-23 fiscal year. The district’s 2022-23 first interim report projected a $4.6 million deficit in 2022-23; the district did not project the additional AB 181 funding. At the time of fieldwork, it did not appear that the district was going to meet all the conditions that would qualify it to receive the funding. 7. Second Interim Report 2021-22: The county administrator approved the 2021-22 second interim financial report on March 9, 2022 with a positive certification. The district’s narrative accompanying its second interim report stated that the district’s fiscal condition is improving as a direct result of fiscal planning and monitoring, support from AB 1840, and reductions in expenditures due to declining enrollment and in alignment with the FSP. The district’s MYFP report shows that it included unallocated expenditure reductions of $4.8 million in 2022-23 and $5.0 million in 2023-24. The county office’s second interim letter described these reductions as unidentified and unapproved expenditure reductions. While the district’s second interim report reflects total available reserves of 3.0% for the current and two subsequent fiscal years, it included an assigned amount of $34.1 million in 2021-22, $30.5 million in 2022-23 and $24.5 million in 2023-24. When the MYFP is adjusted to exclude the unallocated expenditure reductions, the district’s general fund reserve percent for 2022-23 and 2023-24 decreases to negative 0.31% and negative 3.72%, respectively. Since the district’s second interim report was certified as positive, the district was not required to submit a third interim report. On April 28, 2022, the county office completed a review of the district’s second interim report and concurred with the district’s positive certification, which included the FSP cost savings and expenditure reductions of $4.9 million in 2022-23 and an additional $1.1 million in 2023-24. The county office letter also expressed concerns with the projected trend of deficit spending and its impact on the district’s ability to manage long-term fiscal stability. The county recognized that the assigned fund balances could offset the unallocated reductions as mentioned above and raise the negative reserve percentages to required levels, but it cautioned the district about the use of fund balance, a one-time source of Financial Management 319 funds, to offset ongoing expenditures. Therefore, the county superintendent required an updated FSP identifying the specific expenditure reductions and/or revenue enhancements that comprise the unallocated reductions and reflect any implemented adjustments in the district’s 2022-23 adopted budget. 8. Adopted Budget 2022-23: The district’s adopted budget includes an assumptions narrative; however, as stated previously, the district is not consistent with the extent of details provided and lacks detailed assumptions that explain adjustments for the two subsequent fiscal years. The county administrator approved the district’s 2022-23 adopted budget on June 29, 2022. Although the unrestricted general fund budget projected a deficit of approximately $6.4 million in 2022-23, $500,000 in fiscal year 2023-24 and $7.3 million in 2024-25, the adopted budget submitted to the county superintendent showed a reserve for economic uncertainties of 3.14% for 2022-23, 3.10% for 2023-24, and 3.03% for 2024-25. However, the district also included amounts in its components of ending fund balance categories committed and assigned totaling $25.5 million in 2022-23, $25.5 million in 2023-24 and $18.8 million in 2024-25. The district’s adopted budget also projected operating deficits of approximately $39,000 in the child development fund (fund 12), $900,000 in the cafeteria fund (fund 13), $15.0 million in the building fund (fund 21), $1.07 million in the capital facilities fund (fund 25), and $970,000 in the special reserve fund for capital outlay projects (fund 40). In a letter dated September 14, 2022, the county superintendent approved the district’s adopted budget. However, the county office letter pointed out that the district must continue to implement the cost savings and expenditure reductions identified in its FSP along with facility realignment to sustain fiscal stability. The county office required the district to submit an updated plan with its 2022-23 first interim report and requested that the updated FSP include the implementation status and alternative options for contingent reductions. Additionally, the county office had concerns with the district’s declining enrollment, deficit spending, charter school oversight requirements and cash flow. The district continues to experience declining enrollment reportedly caused by both declining birthrates and the number of students who reside within district boundaries. Additionally, the number and size of charter schools that operate both within and outside of, but adjacent to, the district’s boundaries have a direct impact on enrollment. As stated in the county letter, the district reflects declining enrollment of 6,285 for 2022-23, 5,990 for 2023-24, and 5,809 for 2024- 25 with projected funded three-year average daily attendance (FADA) of 6,741, 6,468 and 5,828, respectively. The estimated impact on the district’s projected FADA reflects a two-year loss totaling 913 FADA, representing a 13.54% decrease from the district’s 2022-23 FADA. 9. First Interim Report 2022-23: Interviews with staff indicated that the district used consultants to assist with year-end closing and to complete the development of its 2022-23 first interim financial report. When asked about the details used in the preparation of each of the reports, staff clearly had limited understanding. As stated in previous years, it is concerning that consultants are being used to perform core business functions rather than training staff to build the capacity within the district. 320 Financial Management The district provided FCMAT with a budget narrative for the first interim report; however, the narrative was not included as an attachment to the district’s board agenda. The document has many errors and typos, and some of the rates listed in a table provided for MYFP assumptions do not match guidelines as recommended by the county office in bulletin 6608. One example is the Mandate Block Grant revenues; the district’s assumption table shows a COLA increase in revenues for the two subsequent fiscal years. This may lead readers to believe that revenues will increase by the COLA for the projected years. However, these funds are allocated based on a per-pupil amount multiplied by the various grade span ADA. Although the COLA is applied to the per-pupil amount, since the district is declining in enrollment, and therefore also ADA, the application of the COLA to prior year revenues without also accounting for the reduced ADA will result in an overprojection of revenues. The county office bulletin lists the rates per ADA by grade span. Additionally, the values listed on the district’s assumption table for unrestricted and restricted lottery revenues per ADA and CPI rates are different from the rates found in the county office bulletin. As stated previously, the district is not consistent with the extent of details provided and lacks detailed assumptions that explain adjustments for the two subsequent fiscal years. The district did not include details regarding the ADA projections used in the multiyear projections, nor did the assumptions comment on the district’s current attendance rate as it compares to prior fiscal years, which also affects the district’s LCFF revenues. The county administrator approved the district’s 2022-23 first interim report on December 14, 2022 with a positive certification. The district’s MYFP showed a reserve for economic uncertainties of 3.00% for 2022-23, 3.00% for 2023-24, and 3.00% for 2024-25. However, the district also included an amount of $21.88 million in 2022-23, $18.08 million in 2023- 24 and $7.63 million in 2024-25 as committed and/or assigned as part of its components of ending fund balance. The district projects to deficit spend in the unrestricted general fund by $4.16 million in 2022-23, $3.72 million in 2023-24 and $10.82 million in 2024-25. Based on a review of the first interim, FCMAT is concerned that it does not appear that supplies and services expenditures were increased or decreased in either subsequent fiscal year or adjusted by the standard consumer price index. In fact, both subsequent fiscal years’ expenditures remained flat. Additionally, the district’s 2022-23 first interim report submitted to the county superintendent included an updated FSP, reflecting expenditure reductions totaling approximately $5.83 million in 2023-24, and an additional $10.1 million in expenditure reductions in 2024-25. Based on FCMAT’s review of the MYFP and FSP, the district does not appear to have included the planned cost reductions in the two subsequent fiscal years’ projections. Instead, the district’s MYFP included unallocated expenditure reductions of $2.11 million in 2023-24 and $4.07 million in 2024-25. These arbitrary amounts placed into the budget have a direct correlation to the district’s ability to meet the required reserve for economic uncertainties. When the MYFP is adjusted to exclude those unallocated expenditure reductions, the district’s general fund reserve percent for 2023-24 and 2024-25 decreases to 1.86% and negative 0.51%, respectively. The county office completed its review of the district’s first interim report and the updated FSP and concurred with the district’s positive certification. In a letter dated February 1, 2023, the county office stated that the district confirmed that cost savings and expenditure reductions as outlined in the most recent FSP were recognized only in the current year. Financial Management 321 The district was instructed to update the FSP and include it with its 2022-23 second interim report, along with the implementation status of the planned reductions and alternative options for contingent expenditure reductions and revenue enhancements. The county office noted that the district’s unrestricted general fund is projected to decrease from a beginning balance of $31.8 million in 2022-23 to a projected ending balance of $13.10 million in 2024-25, a decline of approximately $18.70 million, or 58.10% over three years. The county office is concerned about the projected trend of deficit spending and its impact on the district’s ability to maintain the required reserve for economic uncertainties in future years. The county office recommended that the district monitor the causes for deficit spending to prevent further erosion of the fund balance. As stated in the county letter, the district’s first interim report reflects declining enrollment of 7,215 for 2022-23, 6,895 for 2023-24, and 6,681 for 2024-25 with projected FADA of 7,521, 7,129 and 6,335, respectively. The estimated impact on the district’s projected FADA reflects a two-year loss totaling 1,186 FADA, representing a 15.77% decrease from the district’s 2022-23 FADA. Recommendations for Recovery 1. A comprehensive detailed list of MYFP assumptions should be included in the budget and interim report documents that are presented to the county administrator/board at each reporting period. 2. The district should communicate to all those affected the foreseeable impact of the diminished LCFF revenues because of the declines in enrollment and ADA. 3. To provide for greater accuracy and more detailed financial planning, the district should develop its MYFPs at the resource level. 4. Presentation materials provided to the county administrator/board at each budget reporting period should include details for the two subsequent fiscal years that reflect the district’s financial position. 5. Assumption narratives should be included in the online board agenda backup materials. 6. The district should continue to identify measures to enhance revenue and/or reduce expenditures and eliminate its structural deficit. 7. The district should refer to the county office guidelines provided for each financial reporting period and use the assumptions in its MYFP. 8. The district should discontinue applying nonspecific and unallocated expenditure reductions in its MYFP. 9. The district should not rely on one-time reserves for ongoing costs. 322 Financial Management 10. The district should review all budgets and actual expenses at least monthly and make necessary adjustments to help prevent variances between budgeted and actual expenses at year-end and accurately complete multiyear financial projections. 11. The district should monitor and update the FSP to ensure its reserves for economic uncertainties are met. 12. District staff should be trained to prepare and monitor budget and interim reports and MYPFs rather than relying on consultants to do this important work. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 3 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 4 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 323 12.2 Multiyear Financial Projections Legal Standard The governing board ensures that any guideline developed for collective bargaining fiscally aligns with the LEA’s multiyear instructional and fiscal goals. Multiyear financial projections are pre- pared for use in decision-making, especially whenever a significant multiyear expenditure com- mitment is contemplated, including salary or employee benefit enhancements negotiated through the collective bargaining process. (EC 42142) Findings 1. The latest multiyear financial projection prepared by the district should not be used to project costs associated with possible negotiation scenarios due to the concerns identified in Standard 12.1. As stated in Standard 12.1, the district did not include all assumptions used in the development of the 2022-23 first interim MYFP. Additionally, the district included nonspecific and unallocated expenditure reductions in both subsequent fiscal years of the MYFP; therefore, any analysis based on the MYFP to project the impact of a salary increase would be skewed. As previously discussed, consultants prepared the district’s 2022-23 first interim financial report and MYFP. The lack of understanding by district staff hinders any analysis of the ongoing effects of any salary increases under consideration. 2. Between February and June 2022, the district settled negotiations with its certificated and classified bargaining units and with Inglewood Management Association (IMA), its unrepresented management and confidential employee group. The agreements reached were equivalent to a 6% increase effective July 1, 2021 and an additional 4% increase effective July 1, 2022. The district completed the AB 1200 disclosures as required by GC 3547.5(a), and the county office responded to each of the disclosures and concluded that the district would meet its minimum reserve requirements but cautioned the district to implement reductions as outlined in its FSP. 3. During this review period, the district approved several memorandums of understanding (MOUs) as further discussed in standard 14.1. No documentation was provided to FCMAT to demonstrate that the impact to the budget and MYFP was analyzed before approval. Recommendations for Recovery 1. The district should ensure that multiyear projections are adequately supported with ongo- ing revenue enhancements and/or expenditure reductions that are sustainable. 2. Cost analyses and multiyear financial projections should be prepared for use in decision- making when an expenditure commitment is contemplated, including salary and benefit enhancements negotiated through the collective bargaining process. 324 Financial Management 3. The district should include a clear and detailed list of assumptions and a detailed narrative for the MYFP at each reporting period and include that information in its budget presen- tation materials. These should integrate the budget and FSP into the MYFP. 4. The district should ensure staff are trained and knowledgeable regarding the details of the budget and MYFP and can accurately analyze the multiyear fiscal impact of any proposed salary or benefit increases. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 1 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 325 14.1 Impact of Collective Bargaining Legal Standard Public disclosure requirements are met, including the costs associated with a tentative collective bargaining agreement before it becomes binding on the LEA or county office of education. (GC 3547.5 (b)) Findings 1. Before a public school employer enters into a written agreement with an exclusive representative, GC 3547.5(a) requires the major provisions, including costs for the current and subsequent years, to be disclosed at a public meeting in a format prescribed by the superintendent of public instruction. GC 3547.5(b) requires the superintendent (in this case the county administrator) and CBO to certify in writing that the cost incurred under the proposed agreement can be supported financially. This certification must be prepared in accordance with EC 42130 and 42131 and must itemize any budget revision(s) necessary to support the costs of the agreement in each year of its term. 2. GC 3540.2 provides for the added oversight of collective bargaining. It requires that a district with a qualified or negative budget certification pursuant to EC 42131 allow the county office of education at least 10 working days to review and comment on any proposed agreement between the exclusive representative and the public school employer before it is ratified by the board. While this requirement is established in statute, LACOE requires all districts within the county to submit all public disclosure forms to the county office for review at least 10 working days prior to the date the governing board will take action, as stated in its Informational Bulletin No. 6570 dated July 20, 2022. The bulletin also states that a “Public Disclosure form must be prepared for all agreements, including those for no increase or a decrease in compensation,” which suggests that any tentative agreement and/or MOU should comply with the public disclosure requirements. 3. The district’s employees are represented by the following bargaining units: • The ITA represents certificated employees such as teachers, special project coordinators, librarians, counselors and nurses. (ITA successfully petitioned to represent the adult education teachers, and ITA settlements have included adult education teachers since 2016-17.) • As of March 4, 2022, California Teamsters Local 911 represents classified employees. 4. In October 2021, CalPro, otherwise known as Painters and Allied Trades, notified the district that it would no longer represent the Inglewood classified employees, and an election was held to certify a new union. Interviews confirmed that on March 4, 2022, the majority of the classified school employees voted to join California Teamsters Local 911. The provisions of the existing CalPro agreement will continue to govern the employment relationship between the district and classified employees until a new contract is approved. 326 Financial Management 5. IMA is an unrepresented employee group, who typically meets and confers with the county administrator monthly. Although there is no collective bargaining for unrepresented employee groups or individuals, settlements with these employees should be disclosed in the same manner as required under GC 3547.5(a). The need for publicly disclosing all increases to salaries and benefits openly and transparently is a vital function of the district. 6. On December 14, 2021, the district negotiated a tentative agreement with ITA that was ratified by its members on January 28, 2022. The agreement made numerous changes to various articles and revised the term of the contract to July 1, 2021 through June 30, 2024. The tentative agreement also included the restructure of the certificated salary schedule, retroactive to July 1, 2021, which was equivalent to an overall 6% increase. An additional 4% salary schedule increase was effective July 1, 2022. According to the February 16, 2022 board meeting minutes, the county administrator approved an AB 1200 disclosure for the agreement between ITA and the district; however, the public disclosure document was not included in the online board agenda backup materials. The district did not provide FCMAT with a copy of the signed disclosure certification form. 7. The county office responded to the district’s AB 1200 disclosure on February 15, 2022 stating that the agreement “right-sizes” the district’s salary schedule and provides equality across salary steps. The county office concluded that per the district’s analysis and as reflected in the disclosure, the district will meet the minimum reserve requirements during the term of the agreement. 8. The district completed an AB 1200 disclosure for the Inglewood Management Association and presented it during the May 11, 2022 board meeting. Per the disclosure board agenda description, the same provisions provided to the ITA, which increased the salary schedules on average by 6%, effective July 1, 2021 with an additional 4% increase effective July 1, 2022, will be provided to confidential and management employees. The county administrator and CBO signed the disclosure form certification. The county office responded to the district’s AB 1200 disclosure on May 9, 2022 stating that the total ongoing increase in compensation is approximately $760,000. The county office concluded that although the district’s analysis, as reflected in the disclosure, projects it can maintain the minimum reserve requirements during the term of the agreement, the district should implement reductions to conform to its FSP. 9. On May 13, 2022, the district negotiated a tentative agreement with the California Teamsters Local 911, which was ratified by its members on May 19, 2022. Per the disclosure board agenda description, the agreement included the restructure of the classified salary schedule, retroactive to July 1, 2021, which is equivalent to an overall 6% increase with an additional 4% increase effective July 1, 2022. An AB 1200 disclosure was approved during a special board meeting on June 1, 2022. The county administrator and CBO signed the disclosure form certification. The county office responded to the district’s AB 1200 disclosure on June 1, 2022 stating that the total ongoing increase in compensation is approximately $1.89 million. It Financial Management 327 concluded that although the district’s analysis, as reflected in the disclosure, projects it can maintain the minimum reserve requirement during the term of the agreement, the district should implement reductions to conform to its FSP. 10. As previously stated, LACOE requires that a public disclosure form must be prepared for all agreements with represented and unrepresented employee groups, including those for no increase or a decrease in compensation. However, a public disclosure form is not required for salary revisions for individual positions/classifications or contracts for executive cabinet members. During the current review period, numerous salary schedule revisions for individual positions and contract amendments for executive cabinet members were approved. FCMAT’s review of board agendas and minutes found multiple agreements with represented and unrepresented employee groups were approved without the accompanying disclosure form. The following table represents the various memoranda of understanding, salary schedule changes, and letters of understanding that were approved during the current review period without a public disclosure. Group Board Meeting Date Board Agenda Description Approval of Memorandum of Understanding (MOU) Between the Inglewood ITA February 16, 2022 Teachers Association (ITA) and the Inglewood Unified School District, Classroom Coverage Approval of Memorandum of Understanding (MOU) Between the Inglewood Teachers Association (ITA) and the Inglewood Unified School District (IUSD) For ITA April 20, 2022 Teacher On Special Assignment (TOSA) To Serve as Testing Coordinators For The Duration of Spring 2022 at Schools That Do Not Have an Assistant Principal Approval of Memorandum of Understanding (MOU) Between the Inglewood Teachers Association (ITA) and the Inglewood Unified School District (IUSD) ITA April 20, 2022 to Obtain an Administrative Services Credential In Order to Become a Site Administrator Approval of Memorandum of Understanding Between the Inglewood Unified ITA June 1, 2022 School District and the Inglewood Teachers Association (ITA), Teaching More Than Three Preparations During the 2021-2022 School Year Ratification of Memorandum of Understanding (MOU) Between the Inglewood ITA September 14, 2022 Teachers Association (ITA) and the Inglewood Unified School District, LCFF TK-3 Grade Span Adjustment Ratification of Memorandum of Understanding (MOU) Between the Inglewood ITA September 14, 2022 Teachers Association (ITA) and the Inglewood Unified School District - Excessive Class Sizes Approval of Memorandum of Understanding (MOU) Between the Inglewood ITA October 5, 2022 Teachers Association (ITA) and the Inglewood Unified School District, Childhood Development Center Teacher Extra Duty Pay 328 Financial Management Amendment to Memorandum of Understanding (MOU) Between the Inglewood ITA November 2, 2022 Teachers Association (ITA) and the Inglewood Unified School District, Classroom Coverage Approval to Change the Salary for All K-5 and K-6 Principals to the Salary of K-8 Mgmt/Conf August 10, 2022 Principals Approval of Memorandum of Understanding (MOU) Between Inglewood Unified Teamsters June 22, 2022 School District and Teamsters Local 911 - Summer 2022 Work Schedule Approval of Memorandum of Understanding (MOU) Between Inglewood Unified Teamsters August 24, 2022 School District and Teamsters Local 911 – Health and Welfare Benefits Ratification of Memorandum of Understanding (MOU) Between Inglewood Teamsters September 14, 2022 Unified School District and Teamsters Local 911 - COVID - 19 One Time Funds Acceptance of Letter of Understanding between Inglewood Unified School Teamsters November 2, 2022 District ("Employer") and Teamsters Union Local No. 911 ("Union”) Approval of Memorandum of Understanding (MOU) Between the Teamsters Teamsters January 11, 2023 Local 911 and Inglewood Unified School District, Overtime Guaranteed Hours for Afterhours Meeting Technology Support Recommendations for Recovery 1. The district should clearly communicate to all bargaining units the parameters of the roles, relationships and responsibilities of those involved with loss of local control as it affects binding agreements. Once a school district loses local control, the county office of education is the oversight agency, with the concurrence of the SPI and the president of the State Board of Education. The county administrator’s role and responsibilities are subject to the discretion of the county office, including the authorization to enter into binding agreements. Communication with the county office is also of vital importance during the AB 1200 process. 2. The district should fulfill requirements regarding all collective bargaining agreements including GC 3547.5 (a) (b) and EC Code 42130-42131. The county administrator and CBO should sign the disclosure form certifying that the district can meet the costs incurred under the agreement during the term of the agreement. 3. The district should prepare public disclosures, including MYFPs, for all agreements reached with employee bargaining units and unrepresented groups. The AB 1200 disclosure documents should be included with the online board agenda backup materials to inform the public of the costs associated with the agreement. The role of the district public disclosures as required by AB 1200 and AB 2756, including multiyear financial projections, for all agreements reached in accordance with GC sections listed above is of paramount importance. Financial Management 329 4. Extra care should be taken to ensure that oversight agencies have the full 10-day period to review the filing for accuracy. 5. The district should follow the GC 3547.5(a)-(b) disclosure requirements for unrepresented employee groups, such as IMA and others. 6. All information provided in the AB 1200 public disclosure forms should be checked for accuracy before inclusion in the board agenda documentation. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 7 July 2018 Rating: 7 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 330 Financial Management 14.2 Impact of Collective Bargaining Legal Standard Bargaining proposals and negotiated settlements are “sunshined” in accordance with the law to allow public input and understanding of employee cost implications and, most importantly, the effects on the LEA’s students. (Government Code 3547, 3547.5) Findings 1. GC 3547(a) requires all initial proposals of exclusive representatives and the school district to be presented at a public meeting. Additionally, GC 3547(b) prohibits meeting and negotiating from taking place until a “reasonable time has elapsed after the submission of the proposal to enable the public to become informed and the public has the opportunity to express itself regarding the proposal at a meeting of the public school employer.” This section of the GC requires the district’s initial proposals to be adopted by the public employer after the public has had the opportunity to express itself, and any new subjects arising from negotiations after the initial proposals must be made public within 24 hours. 2. The district’s contract with ITA requires the association to notify the district of its intent to modify, amend, or terminate the collective bargaining agreement by presenting its initial proposal to the public during a board meeting no later than March 15 of the calendar year in which the agreement expires. A public hearing is to take place within two regular board meetings from the initial presentation for public comment. After the public hearing, the district is required to respond to the initial proposal within two regular board meetings. 3. FCMAT’s review of board agendas and minutes found that on December 14, 2022, ITA submitted an initial proposal dated December 8, 2022 requesting to reopen negotiations for a one-time off-schedule increase. The district did not hold a public hearing allowing for public comment. 4. The CalPro bargaining unit contract expired on June 30, 2021. A sunshine proposal dated March 23, 2022 was sent to the district requesting to open negotiations for a new collective bargaining agreement between Inglewood Unified School District and California Teamsters Local 911 to be effective from July 1, 2021 to June 30, 2024. The proposal requested to sunshine the prior CalPro collective bargaining agreement Article I through Article XXVIII, including Appendices A and B. On April 20, 2022 the district held a public hearing allowing for public comments regarding the acceptance of California Teamsters Local 911 initial proposal. The district accepted the initial proposal later in the same meeting. 5. On August 10, 2022, the district held a public hearing to sunshine the initial proposal dated June 16, 2022 of California Teamsters Local 911 requesting to open negotiations to establish a new collective bargaining agreement from July 1, 2022 to June 30, 2025. The proposal requested to negotiate Articles I through XXVII and Appendices A and B. The district accepted the initial proposal later in the same meeting. Financial Management 331 6. FCMAT’s review of board agendas and minutes did not find any documentation that the district submitted proposals on its behalf. Recommendations for Recovery 1. The district should ensure it sunshines all collective bargaining proposals and agreements subject to public disclosure requirements articulated in GC 3547 and 3547.5. 2. Any agreed-upon exceptions to contract terms and timelines should be memorialized in writing. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 332 Financial Management 14.3 Impact of Collective Bargaining Professional Standard The LEA has developed parameters and guidelines for collective bargaining that ensure that the collective bargaining agreement does not impede the efficiency of LEA operations. Management analyzes the collective bargaining agreements to identify any characteristics that impede effec- tive delivery of LEA services. The LEA identifies those issues for consideration by the governing board. The governing board, in developing its guidelines for collective bargaining, considers the impact on LEA operations of current collective bargaining language, and proposes amendments to LEA language as appropriate to ensure effective and efficient service delivery. Governing board parameters are provided in a confidential environment, reflective of the obligations of a closed executive board session. Findings 1. To strive for organizational effectiveness and efficient service delivery, it is important to consider how collective bargaining language affects district operations and propose amendments to the language as appropriate. Effective administrations involve supervisory staff in discussions on potential contract modifications or eliminations of positions with bargaining units and unrepresented personnel. FCMAT’s interviews indicated that district administration sought input to the collective bargaining process from principals and other management personnel during this review period. 2. To provide fiscal, employee management and program support, an effective bargaining team includes members who represent various perspectives and disciplines and are aware of characteristics in contracts that impede effective delivery of LEA services. This team ap- proach allows multiple perspectives and differing opinions on how to modify agreements to best meet district goals and objectives. The district’s certificated negotiating team consists of the chief HR officer, executive director of HR & risk management, CBO, CAO, executive director of federal and state programs, two principals, and the district’s legal counsel. The district’s classified negotiating team includes the chief HR officer, executive director of HR & risk management, a director, and the CBO when available. Interviews indicated that administration, including district cabinet, principals and directors meet monthly to discuss various topics related to negotiations. 3. In a prior review period, the district established a standing Health Insurance Committee, consisting of nine representatives with three members chosen by ITA, three by CalPro, and three by the district. Interviews indicated that the benefits committee is now com- posed of two representatives from ITA and the district chief HR officer. The committee’s purpose is to identify options for reducing health benefit cost increases. The district also works with a third-party benefits administrator, Burnham Benefits Insurance Services, to assist in this endeavor. The Health Insurance Committee continues to meet and is consid- ered a source of input in negotiations. Financial Management 333 4. As discussed in Standard 14.1, the district approved several MOUs, a letter of understand- ing, and a salary schedule revision for an unrepresented employee group. No documen- tation was provided to FCMAT to show that the impact to the budget for the proposed MOUs, letter of understanding, and salary schedule revision for an unrepresented em- ployee group was analyzed before consideration. 5. A review of board minutes showed that confidential discussions on negotiations are listed in the blanket statement for closed-session meetings; however, in the prior review period, only the January 12, 2022 board minutes for closed session show an update regarding negotiations with ITA. In the current review period, there was no indication on board agendas or minutes that negotiations were discussed in closed session. Recommendations for Recovery 1. The input process for developing initial proposals before they are presented at a public hearing should continue to be inclusive in identifying characteristics in contract language to ensure effective delivery of district services and meet the needs of all schools. 2. The district should evaluate decisions and their multiyear impact on all collective bargaining agreements as well as any memoranda of understanding. 3. The district should continue to formally communicate and train managers regarding the impact of all contract modifications. District administration should issue a joint statement in conjunction with bargaining units on the impact of a given settlement on its employees. If a joint statement is not possible, a formal district announcement, recapping the major impacts of the settlement would help increase communication and understanding. 4. The district administration should monitor the actions of the advisory Health Insurance Committee to ensure there is no adverse impact to the district. 5. The district should continue to ensure that the CBO is a member of all its collective bargaining teams and ensure that the CBO attends all collective bargaining sessions. 6. The district should ensure that if negotiations are discussed in closed session, it is disclosed on the board meeting agenda and if action is taken, it is disclosed in the board meeting minutes. 334 Financial Management Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 5 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 6 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 335 15.2 Management Information Systems Professional Standard Management information systems support users with information that is relevant, timely, and accurate. Assessments are performed to ensure that users are involved in defining needs, develop- ing specifications, and selecting appropriate systems. LEA standards are imposed to ensure the maintainability, compatibility, and supportability of the various systems. The LEA ensures that all systems are SACS-compliant, and are compatible with county systems with which they must interface. Findings 1. A District Information Technology Advisory Committee (DITAC) was created several years ago to guide the district in its use and selection of technology. The executive director of IT leads the DITAC meetings, and committee members include lead technology teachers, principals, cabinet members, department leads, and senior IT staff. Meeting agendas, minutes, and other related materials are distributed via email to all committee members. The DITAC committee was disbanded in 2020, and between 2020 and January 2022, the Instructional Technology Committee (ITC) was convened in its place. The ITC meetings address educational and classroom technology topics and are led by the CAO and the director of educational technology. Members of the IT Department attend and contribute to the ITC proceedings. In early 2022, the district reconvened the DITAC, and the committee met regularly during the 2022-23 school year. 2. On January 26, 2022, the county administrator/board approved a realignment and reorganization of technology support. The executive director of IT now reports to the CBO instead of the CAO. Along with the executive director, other IT staff transferred to the business office, including those responsible for network infrastructure, CALPADS processing, and Aeries attendance/enrollment/class scheduling. A newly created position of director of educational technology reports to the CAO. All site-based and district office-based computer technicians report to the director of educational technology. The executive director of IT and the director of educational technology work closely together as their teams share a common mission and deal with similar and related areas of operations. 3. The executive director of IT and the director of educational technology routinely attend LCAP planning meetings where technology use, as noted in the plan, is discussed. These meetings have helped the Educational Services and IT staff to understand better how they can work together to improve IT and educational technology (EdTech) services in the district. 4. The district hired a 1.0 FTE database administrator (DBA) during the 2016-17 fiscal year to provide data integration support and primary support for CALPADS processing and reporting. The DBA made notable progress in automating data transfers between HRS, Aeries, and Nutrikids and eTrition child nutrition systems, and improved the error reconciliation reporting, which resulted in a significant decrease in manual tasks previously required for compiling and reporting CALPADS data. The automated process 336 Financial Management also increased the probability of CALPADS data accuracy because the potential for human error had been reduced and improved data verification processes had been implemented. In September 2020, the DBA resigned, and the position remained vacant until it was filled in June 2021. In mid-2022, the position became vacant again and remained so until late 2022. In 2022, a second DBA position was created; however, it remains vacant. The district filled one of the vacant DBA positions in late 2022 when the position was offered to the district’s application support technician. The district’s application support technician position is vacant. The district’s one DBA splits time between the application support technician duties and DBA responsibilities while working with the district’s CALPADS reporting contractor for DBA and CALPADS training. 5. Starting in October 2020, the district has maintained an annual contract with the former DBA, to provide support for processing CALPADS data. The cost of the current year contract has been amended three times during the 2022-23 fiscal year. The original six-month contract, entered into on July 1, 2022, was for $17,500 and was set to end on December 31, 2022. The contract was first amended to increase the not-to-exceed amount by $30,000 on September 14, 2022, taking the total to $47,500 and keeping the ending term of December 31, 2022. The second amendment took place on November 2, 2022, and increased the not-to-exceed amount to $77,500, a $30,000 increase. A third amendment to extend the term of the contract to July 31, 2023 and increase the not-to-exceed amount by another $30,000 was approved on January 25, 2023, taking the total not-to-exceed amount to $107,500. 6. The district uses the services of a second contractor to support its student information system, Aeries (SIS), and to assist with its CALPADS obligations. The contract for services was ratified on August 10, 2022 and authorized the contractor to perform SIS and state reporting consulting services from July 1, 2022 through June 31, 2023. The not-to-exceed amount for this contract is set at $60,000. 7. The district uses the BEST financial management software provided by LACOE that complies with SACS for uniform statewide financial reporting. Recommendations for Recovery 1. The district should continue the DITAC meetings to ensure that all parties have an opportunity to speak, listen, learn, and guide the use of technology. The ITC meetings should continue as needed, and cooperation and collaboration between the two committees should continue. 2. The district should fill the vacant DBA position. The second DBA position should be tasked with supporting state reporting (CALPADS) and support of the SIS. 3. The district should ensure that the existing DBA staff member is fully trained to meet the district’s state-reporting needs. Financial Management 337 4. The district should minimize its reliance on third-party contractors for critical and time- sensitive state reporting responsibilities. Instead, the district should develop internal capabilities and capacity to ensure timely and accurate state reporting and the integrity of the district’s data systems. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 3 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 5 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 338 Financial Management 15.3 Management Information Systems Professional Standard Automated systems are used to improve accuracy, timeliness, and efficiency of financial and report- ing systems. Needs assessments are performed to determine what systems are candidates for auto- mation, whether standard hardware and software systems are available to meet the need, and wheth- er or not the LEA would benefit. Automated financial systems provide accurate, timely, relevant information and conform to all accounting standards. The systems are designed to serve all of the various users inside and outside the LEA. Employees receive appropriate training and supervision in system operation. Appropriate internal controls are instituted and reviewed periodically. Findings 1. A CALPADS processing team consisting of the two DBAs, an application support technician, select staff from the business office, and the executive director of IT are responsible for CALPADS reporting. At the time of FCMAT’s fieldwork, one of the DBA positions and the application support technician position were vacant. The district also uses the services of two contractors for assistance with CALPADS and other SIS-related services. Essential members of the CALPADS processing team reported significant gaps in their knowledge of the processes and procedures associated with CALPADS reporting, including data verifications, error correction, and the certification process. In addition, district CALPADS staff reported being dependent on the services of the district’s CALPADS contractors for both services and training the recently hired DBA team member. 2. At the time of FCMAT’s fieldwork, the district failed to certify CALPADS, missing both the fall 1 certification deadline of December 16, 2022, and the fall 1 amendment window deadline of January 27, 2023. The district provided FCMAT with a document titled CALPADS Process and Procedures for IUSD. The document states the following: Purpose: This plan provides direction for IUSD’s preparation for all CALPADS submissions throughout the school year, defining scope, roles and responsibilities, calendar and timeline, and alignment to FCMAT findings and recommendations. This 40-page document is much improved over the draft version of the same document received during a prior review period. This latest version contains, among other new details, timelines and areas of responsibility for data collection and review. The document is a sound foundation for documenting the district’s CALPADS processes and account- ability. 3. The district still lacks a comprehensive professional development plan for many of its information systems. FCMAT was provided a document titled Inglewood Unified School District Technology Plan 2020-2024, Implementation Plan. The CAO, executive director of special education, executive director of information technology, and the director of educational technology provided an update on the status of the district’s draft technology plan to the board of education and county administrator at the March 9, 2022 board meeting. The update provided information regarding teacher and student impressions of Financial Management 339 the technology assessed and summarized using BrightBytes, an IT- and EdTech-specific staff and student surveying tool. The information in the presentation is classroom- and instruction-centric and includes data on student and staff technology needs and EdTech skill proficiency levels. The update also references several ongoing EdTech initiatives and technology projects. The update does not include project statuses, timelines, or budgets for any initiatives or projects. The update provided no details or specifics regarding the items designated as the next steps, and no other supporting documentation related to professional development was provided. 4. School site principals have online access to their site budgets through the county- provided BEST financial system or external Google Sheets reports, and 1-on-1 training in running and interpreting budget reports is available from staff in the business office as requested. The business office no longer emails principals their budget reports monthly in a simplified format via an Access system, instead, it sends Google Sheets-based budget reports monthly. In addition, the business office has monthly meetings with principals to review their budgets, answer questions, and provide training as necessary. These meetings are well-received by the principals. The combination of these methods provides principals multiple avenues to receive up-to-date budget information. At the time of FCMAT’s fieldwork, site staff reported inconsistent proficiency with and use of the BEST system for site financial management purposes. For example, users at some sites reported that they are comfortable using the BEST system and the district provided Google Sheets reports for budget management. In contrast, staff at other sites indicated that they use external resources, such as Excel spreadsheets, to manage site finances. 5. Both the Business Services and HR departments continued to focus on correction of errors in the position control system during this review period. As in previous years, current efforts include identifying and eliminating those open and budgeted positions, which have not or will not be filled. In prior years, HR staff attended position control training provided by the county office to help better understand how the system is used for salary and benefit budget projections. 6. In fall 2017, the district implemented the Informed K12 system, which, among other things, is used for the creation, routing, and approval of personnel action forms. This system has been designed to ensure that any changes to position assignments are monitored and, where needed, updated in the position control system. The current process includes nine steps to fill a position in the system. HR and Business staff reported that they are pleased with how the Informed K12 system is used to process and track the information needed to update position control. Representatives from the Business Services and HR offices reported improved communication between the two offices due to the implementation of the Informed K12 system. 7. The annual audit of the district, performed by Nigro and Nigro for the fiscal year ended June 30, 2021, included finding 2021-007 that the district was not requiring staff password changes at least annually to ensure the safe-keeping and integrity of information systems used by the district. Additionally, the auditors noted seven instances in which former district employees’ access to vital information systems was not removed in a timely manner consistent with their final workday. 340 Financial Management Page 103 of the report for the annual audit of the district, performed by Nigro and Nigro for the fiscal year ended June 30, 2022, noted that Finding 2021-007 has been resolved and the recommendations provided by the audit firm have been implemented. However, during the 2022-23 FCMAT finance team interviews with IT Department staff, the district confirmed that there is no policy requiring regular changes of network passwords. Recommendations for Recovery 1. The district should continue to use the document titled CALPADS Process and Procedures for IUSD, updating it as necessary to reflect changes in both internal procedures and external processing requirements. 2. The district should fill the vacant DBA and application support technician positions and ensure all CALPADS and state-reporting-related staff have adequate training and sufficient knowledge of the district’s systems, data, and workflows to ensure timely and accurate CALPADS certification and the ability to meet other state reporting requirements. 3. The district should continue to assess the EdTech and technology skills of administrators, teachers, and support staff. Data collected during these assessments should be used to develop staff development plans and guide IT infrastructure and user device investments. 4. The district should develop a detailed staff development plan to ensure its administrators, teachers, and support staff know how to use its EdTech and IT resources properly and effectively. 5. The district should finalize its draft technology plan and include timeline, budget and refresh cycle details for all significant infrastructure projects in the plan and board updates. 6. The district should assign district staff, coordinate with the county office, and/or arrange for qualified consultants to regularly provide professional development. The schedule and location of trainings should be posted on the district website, and sign-in sheets for employees who have attended the trainings should be maintained. 7. Resources in the business and HR offices should continue to be focused on correcting errors in position control and keeping information in the system up to date to ensure accurate and efficient payroll generation and budget data. Ongoing efforts to maintain data integrity will require a high-level of coordination between the HR and business offices. The district should continue the meetings between the two departments to address problems and suggest resolutions, and the meetings should be held on a regular and scheduled basis. Staff who use the position control system should be assessed for their knowledge of the system and provided with training if needed. 8. The district should continue to use the procedures developed to ensure HR communicates with IT when an employee separates from employment, and IT should continue its practice of removing that employee’s access from district systems when notified by HR. Financial Management 341 9. The district should develop and implement procedures requiring staff to change passwords at least annually. The district should develop and implement procedures to change the security door passcode at least annually. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 342 Financial Management 15.7 Management Information Systems Professional Standard Hardware and software purchases conform to existing technology standards. Standards for net- work equipment, servers, computers, copiers, printers, fax machines, and all other technology assets are defined and enforced to increase standardization and decrease support costs. Requisitions that contain hardware or software items are forwarded to the technology department for approval before being converted to purchase orders. Requisitions for nonstandard technology items are approved by the information management and technology department(s) unless the user is informed that LEA support for nonstandard items will not be available. Findings 1. The DITAC meets to review hardware and software standards, which are set by mutual agreement between representatives of the ITC and the DITAC. Standards for computer hardware are reviewed only when the existing standardized computer is no longer available from the manufacturer, or special pricing is no longer available. 2. Hardware standards exist for different types of equipment to be used by administrators, teachers, and students and were published on the district’s online Administrative Handbook. They are now published on the district’s IT webpage (IUSD Information Technology webpage) through a link labeled IT Procedures Manual (version 2021.01.13), which the IT Department has created. For security purposes, one must first sign into the district’s Google platform to access the document. The document version provided to FCMAT is outdated and does not reflect the division between the Information Technology Department and the Educational Technology Department. The document also lists incorrect employee titles and does not represent the most updated organizational chart. This document contains, along with other useful information, instructions for how to access quotes for both standard and nonstandard hardware items. Copier standards have also been developed because these devices also serve as fax machines, scanners, and printers. The IT Department has internal documentation on preferences for copiers and replacement network equipment including servers. 3. The districtwide use of the online Administrative Handbook has ceased, and instead, departments populate their respective webpages with the handbook content. This is inconvenient for site users who may not be sure which department has the needed information, and they may have to search various departments’ webpages. It was simpler for users to search a centralized source of information such as the online Administrative Handbook. 4. The use of the BEST financial system for routing technology purchase requisitions for approval has continued to allow the executive director of IT to review all technology purchase requests to ensure conformity. Working together, the business office and IT Department have ensured that all requests for technology acquisition are routed through the BEST system. Requests for nonstandard equipment are made through the IT work order system so that requests and communication between both parties can be documented and processed. Financial Management 343 Recommendations for Recovery 1. The DITAC should continue to work collaboratively with the ITC to formally review and set standards as necessary for both software and hardware. 2. The district should publish an up-to-date IT Procedures Manual document. The docu- ment should reflect the current organizational structure of the Information Technology and Educational Technology departments, reflect the correct staffing information, and include updated IT- and EdTech-related workflows, as well as a complete list of technol- ogy standards for equipment used by administrators, teachers, and students. The district should clearly communicate the location of the information so that all staff are aware that the information is accessible and available online. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 344 Financial Management 15.8 Management Information Systems Professional Standard An updated inventory includes item specification for use in establishing standards for an equip- ment replacement cycle and rotating out obsolete equipment. Computers and peripheral hard- ware are replaced based on a schedule. Hardware specifications are evaluated yearly. Corroborat- ing data from work order or help desk system logs is used when this data is available to determine what equipment is most costly to own based on support issues. The total cost of ownership is considered in purchasing decisions. Findings 1. The district continues to lack a formalized lifecycle replacement plan for critical network infrastructure equipment such as routers, switches, wireless access points, telecommunications electronics, servers, and data storage. The executive director of IT has created a spreadsheet showing critical systems that need replacement with some equipment more than 10 years old and no longer supported by the original vendor. The lack of formal planning will create unplanned expenses and outages when systems cease to function. Technology assets eventually fail, and their replacement schedules should be monitored so the associated expenses can be properly budgeted. 2. The IT Department has used the School Dude Help Desk system since fall 2016. All district employees can submit tickets through this system. The computer technicians are assigned to specific regions, and the system automatically assigns the ticket based on the location of the services requested. Interviews with staff indicated that approximately 85% of all service requests are now processed through the help desk system. Because of the increased volume, not all service requests are formalized and entered in the School Dude (now Brightly) Help Desk system. 3. To bring the district’s actual inventory of items up to date, on February 17, 2021 the county administrator approved a contract with CBIZ Valuation Group, LLC beginning February 18, 2021 and terminating June 30, 2021. The scope of the contract generally details completing an inventory of district assets as defined in the contract under Exhibit A. Approximately 7,587 items were inventoried by CBIZ and can be reviewed in an Excel spreadsheet. Unfortunately, the district has not maintained the newly created inventory or reconciled it against the previous inventory records. 4. In August 2017, the IT Department purchased mobile device management and inventory tools for phones and tablets from School Dude. The department also purchased Insight from the same vendor partly to aid in inventory reconciliation. The Insight product can scan the network and record information on the type of devices it locates. The IT Department has implemented the School Dude Insight module. Reconciliation between School Dude’s Asset Management system and the Insight module is being done to determine what assets have been found that were not recorded in the asset management system. Additional information regarding the physical inventory is contained in Standard 16.1. Financial Management 345 5. The warehouse clerk position was eliminated several years ago, and the tagging/inventory function performed by this position is no longer performed at the warehouse. Individual departments are responsible for tagging assets for their respective departments. During a previous reporting period, the district identified another staff position, the inventory and distribution coordinator, who would assume tagging and inventory management duties. This employee will need significant training to successfully complete these additional responsibilities, but has not received any. 6. As reported in prior review periods, the warehouse does not receive all technology equipment since most shipments are delivered directly to the departments and school sites. Both standards-based equipment such as laptops, Chromebooks and other devices, and nonstandard-based equipment such as special orders, are purchased from the district’s list of value-added resellers (VARs). When equipment is ordered from the VARs, the vendor tags the items prior to shipping and provides the district with an electronic data file containing information such as make, model, serial number, and asset tag number. For all other vendors, the district should have a policy that requires all technology equipment and any other fixed assets to be delivered directly to the district’s warehouse where it can be tagged and inventoried prior to delivery to school sites and departments. The IT Department has an asset tagging procedure for assets purchased from an existing VAR, but it does not include guidelines for tagging equipment delivered to the central warehouse. 7. The district does not track fixed assets per the requirements of EC 35168. This includes many of the district’s IT assets over $500.00. The district does not use a system to track and process its fixed asset depreciation, normally used for end-of-year budget reporting. The district does not conduct a regular physical inventory as detailed in the CSAM Procedure 410. Recommendations for Recovery 1. The district should formalize its strategic vision and planning for the use of the network- ing infrastructure equipment such as routers, switches, wireless access points, telecommu- nication electronics, servers, and data storage to adequately prepare for ongoing expenses needed to keep the system functioning properly. To help ensure funding for future up- grades, the district should formalize and approve a lifecycle replacement plan that is represented in its multiyear budget. 2. The district should ensure that all IT service requests are processed through the help desk system. 3. The district should select a system and adequately train staff to maintain the inventory of its fixed assets per the requirements of EC 35168. 4. The district should have a policy/procedure that requires all technology equipment, except for items ordered through the list of VARs, and any other fixed assets to be delivered directly to the district’s warehouse to ensure that all fixed assets are properly received and tagged for inventory purposes. 346 Financial Management Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 347 15.10 Management Information Systems Professional Standard In order to meet the requirements of both online learning and online student performance assess- ments, the district has documentation that provides adequate technology to support these needs. Documentation should include sufficient bandwidth to each school site, internal local network in- frastructure capacity, electronic devices which meet the published minimum standards for online student assessments, and an adequate number of devices to allow testing of all students within the prescribed amount of time. Findings 1. The district uses Chromebooks to administer the California Assessment of Student Performance and Progress and is generally pleased with their use and performance. Staff in both the Information Technology and Educational Technology departments reported no bandwidth or infrastructure-related problems with the administration of the 2022-23 Smarter Balanced Assessment. 2. The district has adopted a 1-to-1 student-to-device ratio, providing all students with either Chromebooks or iPads for use in the classroom and at home. 3. The district does not use a centralized instructional material inventory system to track the issuance of student devices. Instead, library staff or temporary employees track devices at the site level. 4. The district has adopted digital curriculum materials for its core subjects. Students are expected to use their district-issued devices to access the digital core curriculum and supplemental instructional materials. Textbooks for core subjects are also provided and are often used when deemed appropriate by the classroom teacher. 5. The executive director of IT reports to the CBO and attends all principals’ meetings. 6. The district bandwidth of 10 gigabytes per second (Gbps) to each school site, provided by fiber connectivity, is sufficient, and the impact of assessment testing on the district’s bandwidth to the internet is minimal with a 10 Gbps internet connection to the county office. LACOE is the district’s internet service provider. 7. The district contracts temporary site technicians with AppleOne Employment Services, a temporary employment services company. The temporary site technicians serve as the first layer of technical support for school site staff. The temporary employees are responsible for staff and student device distribution, basic device troubleshooting and repair, as well as assisting users with low-level application and operating system problems. The contract with AppleOne terminates June 30, 2023 and is paid for using one-time pandemic relief funds that expire in the 2023-24 school year unless otherwise extended. Interviews with 348 Financial Management the administrator who oversees the temporary employees, indicate that the district has no plans to fund these positions past the expiration of the COVID relief funds and that the loss of these positions will greatly affect the service levels the district office can provide the sites. Recommendations for Recovery 1. The executive director of IT and the director of educational technology should continue to meet regularly with Educational Services Department staff and attend principals’ meetings to understand the district’s educational goals and align human and fiscal resources to sup- port those goals. The executive director of IT should also continue to meet regularly with the CBO and appropriate business office staff to discuss issues related to the Business Services Department’s technology goals and the financial resources available for technology. 2. The district should develop a staffing and support plan to address the significant gaps in site- level technology support should the contract for temporary site technicians be allowed to expire due to a lack of ongoing funding. 3. The district should fully implement a centralized instructional material tracking system. The system should be used to track all instructional materials, including student devices. Standard Fully Implemented July 2013 Rating: 2 July 2014 Rating: 6 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 7 July 2018 Rating: 8 July 2019 Rating: 9 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 9 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 349 15.11 Management Information Systems Professional Standard The LEA optimizes funding of various types of technology throughout the organization by effec- tive utilization of available Federal E-rate discounts, the California Teleconnect fund, and other available discount programs and funding sources to reduce costs for various technology expendi- tures. Findings 1. The executive director of IT is the primary position responsible for the E-Rate process and works closely with the CBO and the district’s E-Rate consultant to ensure timeliness and compliance with the application process. 2. Beginning in the 2009-10 fiscal year, the district used an independent consultant to pro- vide E-Rate consulting services and prepare district claims. During the 2018-19 fiscal year, the district established a new contract with Infinity Communications and Consulting to provide these services. 3. The district still does not have a specific committee to hold annual E-Rate planning meet- ings with representatives from key departments, including Business, IT, Facilities, Food Services and Educational Services. The purpose of these meetings should be to assess the district’s needs and budget for equipment and services that may be partially funded through the E-Rate process. However, the reestablishment of a DITAC in 2021-22 serves as the source for E-rate-related discussions. Minutes from the September 20, 2022 DITAC meeting show that E-rate Category 1 and Category 2 items were discussed. 4. The district applied for California Teleconnect Fund (CTF) discounts on March 10, 1998 and was approved on July 21, 1999. The executive director of IT stated that as part of the district’s switch to Infinity Communications and Consulting for E-Rate assistance, the vendor audited eligible CTF accounts and determined that the district is receiving CTF discounts on all eligible services. 5. The district’s 2022 E-Rate Form 471, submitted on March 8, 2022, states that the percent- age of students in the district eligible for the National School Lunch Program (NSLP) is 83%, which qualifies the district for an 85% discount on eligible hardware (also known as Category 2 funding) and a 90% discount on eligible internet and data communication services (also known as Category 1 funding). The district’s eligibility percentage for free and reduced-price meals is near threshold levels of E-Rate funding. 6. For the 2022 funding year, which runs from July 1, 2022 to June 30, 2023, the district filed a Form 471 for districtwide internet service and data transport circuits requesting a total of $383,919.19 in internet service provider (ISP) connectivity. No funding commitment letter was provided at the time of FCMAT’s fieldwork. 350 Financial Management 7. For the 2022 funding year, which runs from July 1, 2022, to June 30, 2023, the district filed a Form 471 for Emergency Connectivity Fund (ECF) services. The district requested $513,120 in funding for home-to-school wireless connectivity services for 2,138 T-Mobile hotspots. No Form 470 or Universal Service Administrative Company (USAC) funding commitment letter was provided at the time of FCMAT’s fieldwork. 8. The district, working through its contracted E-rate consultant, Infinity Communications, successfully appealed a Recovery of Improperly Disbursed Funds complaint issued by the USAC late in the 2021-22 fiscal year. The appeal reduced the amount the district owed to the USAC by $23,798.11, for a final post-appeal total of $60,581.57. On April 16, 2021, the district made a $60,581.57 payment to USAC to settle the matter. The district acted cor- rectly in appealing USAC’s decision on the funds owed for the 2015-16 funding year and was able to reduce the amount owed by approximately 25%. Recommendations for Recovery 1. The district should continue to use an outside consultant to provide E-Rate consulting services and prepare district claims. 2. The district should ensure that the executive director of IT discusses in detail with appropriate district leadership the use of E-Rate discounts and timelines. If they cannot perform this function, the district should form an E-Rate committee, which should meet each year in the late summer/early fall to discuss the upcoming E-Rate timeline and potential funding opportunities and to review existing E-Rate discounts to determine if they will be reapplied for in the following year. 3. During the year, key individuals such as those from the Business, IT, Facilities, Food Services and Educational Services departments should meet regularly to better understand the availability of E-Rate discounts and possible funding levels. The district should continue to verify its E-Rate funding levels and have contingency plans for both the amount funded and those deferred on E-Rate applications. 4. District staff should monitor the vendor invoices for the expected E-Rate, ECF, and CTF discounts for eligible services. If expected discounts or credits are not appearing on eligible invoices, the district should immediately contact its E-Rate consulting company to address this issue. 5. The district should continue to monitor its wireless services provider associated with ECF discounted services. As of March 2022, the Federal Communications Commission (FCC) opened the third wave of ECF funding. The third funding wave, for which the district submitted its 2022 application, covers service contracts starting July 1, 2022, and running through December 31, 2023. If the FCC elects not to issue a fourth wave of funding, the district will have to cover the full cost of hotspot contracts that continue after December 31, 2023 or find an alternative way of providing access to students who lack sufficient internet connectivity at home. Financial Management 351 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 352 Financial Management 16.1 Maintenance and Operations Fiscal Controls Legal Standard Capital equipment and furniture is tagged as LEA-owned property and inventoried at least annu- ally. Findings 1. On April 15, 2015, the state trustee approved the services of a vendor to perform a fixed asset inventory and asset management services, which included bar-code tagging, asset exception reporting and providing certified appraisal reports. A physical inventory and tagging generated a fixed asset report published June 30, 2015. During the current and prior review periods, district staff could not provide an additions/deletions list for assets that were obtained or disposed of since the completion of the June 30, 2015 report. On June 22, 2017, the state administrator approved an agreement for School Dude to provide a cloud-based application for IT asset management services. On June 29, 2022, the county administrator/board approved a renewal contract with Brightly Software, Inc. (formerly Dude Solutions) for the 2022-23 fiscal year. At the time of FCMAT’s fieldwork, staff could not provide an inventory list generated by this system. On February 17, 2021, the county administrator approved an agreement with another vendor to perform a capital asset inventory and valuation, barcode tagging, and limited reconciliation to the district’s existing fixed asset list. The vendor provided summary and detailed fixed asset reports along with additions and disposals reports and a fixed asset log in Excel. However, the district did not use the reports to complete Form Asset for its 2020-21 or 2021-22 unaudited actuals. Interviews indicated that the reconciliation of work in progress category of assets has not been completed. On June 30, 2021, the county ad- ministrator approved a supplemental services agreement with the vendor to reconcile the construction in progress account. 2. The district’s 2021-22 independent audit report was presented to the county administrator/board on January 11, 2023. The report includes findings concerning lack of accuracy in recording capital assets and reporting deficiencies. The findings indicate that the district does not maintain adequate source records to support the amount reported as capital assets and related accumulated depreciation in its financial statements. The district does not have controls to ensure that additions, disposals, and depreciation are recorded accurately; therefore, the increases and decreases to capital assets reported on its financial statements could not be substantiated. Additionally, the district recorded capital outlay expenditures of $7.9 million in the general ledger yet reported $8.45 million in increases to capital assets on its financial statement. Findings in the last several annual audit reports include material weaknesses specifically related to inventory and fixed assets. The recommendations have not been implemented, and these findings contributed to the qualified opinion given by the independent auditor on the 2021-22 audit report. Financial Management 353 3. The draft Purchasing Department SOP does not include procedures for tracking inventory; however, the Purchasing Department section of the Business Services Division Procedure Manual states that all equipment valued at more than $500 should be delivered to the warehouse, where it will be tagged, inventoried, and tracked. If equipment must be delivered to the site, warehouse staff is supposed to tag the merchandise at the site; however, interviews with staff indicated that assets delivered directly to the sites have not been regularly tagged. The district continues not to tag donated or nontechnology items, and no evidence indicates that additions and deletions are tracked. The district has not established sufficient receiving procedures and protocols when physical inventory items and/or textbooks are shipped directly to school sites. Interviews with staff indicated they are unaware of the procedures and their responsibilities. The IT and Food Services departments have developed some basic departmental tagging procedures. The Food Services and IT departments receive tags from the warehouse and tag their own assets, and most technology items are tagged by vendors prior to delivery to the district (see Standard 15.8). 4. Several years ago, the warehouse clerk was responsible for tracking items; recording them in a spreadsheet, noting the description, location, serial number, funding information and tag number; and applying the asset tag. However, the state administrator eliminated that position at the April 11, 2018 board meeting, and the inventory listing has not been maintained. On June 29, 2020, the county administrator approved the creation of the new position of inventory and distribution coordinator. Among other duties, this position is responsible for managing the inventory database, updating and tracking district inventory including capital assets and textbooks. Interviews indicated that the inventory and distribution coordinator has no access to the warehouse clerk’s 2015-16, 2016-17 or 2017-18 inventory lists. The district has not implemented a system for asset management nor has the inventory and distribution coordinator received training on asset management. 5. The sale of surplus property is governed by BP 3270 as well as EC 35168, 17540-17542, and 17545-17555, which establish safeguards to account for and protect district-owned property. The EC requires a specific detailed process for disposing of surplus assets and using those sale proceeds. The district salvage procedures in the draft Purchasing Department SOP do not support the reporting requirements in EC 35168, requiring inventory to be tracked as to the time and mode of disposal. It also does not provide proper internal control, possibly allowing valuable items to be disposed of without proper review. 6. FCMAT could not identify the employee or department responsible for overseeing the disposition of district surplus items. Because of frequent staff turnover, it is unclear if employees follow all the district salvage policies and procedures and whether they are knowledgeable of board-adopted policies or the related EC sections. As a result, implementation of BP and AR 3270 could be problematic, particularly the portion related to the salvaging of property valued at less than $2,500. This is because internal controls to determine market value have not been implemented, and the property may be disposed 354 Financial Management of by dumping if someone erroneously determines it is of limited value. Personnel may not know about the regulations regarding disposal of assets and may try to trade in or sell items to a private party. 7. The district has forms for salvage of equipment items and for the collection of discarded books and materials that school sites may use to document obsolete inventory. Forms supporting county administrator/board action show that school sites and departments use the salvage form, but it is frequently not fully completed. Additionally, the information is not used as documentation to support the items sold to salvage or to update the fixed asset list. Many of the forms reviewed were missing serial numbers and/or fixed asset tag numbers. 8. Under the current system, once the county administrator/board approves an item as surplus, it is stored until disposal. However, a surplus inventory list is not maintained. There are no physical controls or procedures to identify the items declared surplus that are not sold to salvage. There are also no procedures to identify if assets are transferred from the site of original purchase and/or delivery. 9. During the current review period, lists of surplus items, including food service equipment, technology equipment, miscellaneous items from school sites and textbooks were declared surplus. The district provided copies of checks and deposit backup; however, the backup did not include sufficient information about the items sold/salvaged/recycled. Therefore, it could not be determined if the proceeds were deposited to the correct fund. 10. EC Sections 60510-60530 and 17547 establish safeguards to account for and protect district instructional materials and their funding, which require a specific detailed process for the disposal and the use of the proceeds. In addition, the federal Office of Management and Budget Circular A-110 states that any funds received for disposal of equipment that was purchased with federal funds must be returned to the original funding source. 11. The funding source column was left blank on many of the Salvage Inventory Sheets used for board backup, so it is unclear if the items are tracked correctly in the surplus inventory or at disposal and if all funds generated are deposited back to the original funding source. 12. The county administrator approved service agreements with TLC Auctions at the November 3, 2021 board meeting for the 2021-22 fiscal year. This is the only surplus property disposal vendor approved for the 2021-22 fiscal year. No vendors were approved for surplus property disposal for the 2022-23 fiscal year. Review of district documents indicated it received recycling revenue from TLC Auctions, SA Recycling, Recycle International, and A&I Pallets. 13. School sites reported they each have their own textbook inventory list, and textbooks sometimes come to the sites with asset tags, but not in all cases. The former textbook clerk left the district several years ago, and the districtwide textbook inventory has not been maintained since she left. Some books are located at the school sites, and some are located at the district office, but the district does not maintain a complete textbook inventory Financial Management 355 including the location of the books. Interviews indicated that if a site requests books, and the inventory and distribution coordinator cannot locate the books at the district office, he will call the other sites to check for unused books. 14. The district uses a textbook inventory tracking software, but it is not fully implemented. Staff reported that one person from each school site received training on the system, but not all sites are using it. District staff indicated in interviews that data entry clerks were assigned at the secondary schools to barcode and enter textbooks into the inventory system, and it was reported that most of the core textbooks were entered. However, the elementary school sites do not have the capacity or personnel to accomplish the textbook inventory. School sites submit a salvage form for obsolete textbooks for inclusion on the board agenda, and after county administrator/board approval, textbooks are picked up from the sites for disposal. However, there is no procedure to remove the books from inventory. Recommendations for Recovery 1. The district should conduct a physical inventory at least every two years and ensure all capital assets valued at more than $10,000 (BP 3400) and other assets valued $500 to $9,999 are fully accounted for in the inventory ledger. In addition, Title 2 of the CFR, Part 200 requires that equipment acquired with federal funds be included in the inventory if the acquisition cost exceeds $5,000. Because the perpetual inventory has not been main- tained since the 2021 physical inventory was conducted, the district should consider an annual inventory until roles and responsibilities are assigned. An exception list should be generated to support internal controls. 2. The independent appraisal company should be provided with a complete list of disposed assets and lost/stolen items for independent verification. 3. All assets valued at $500 or more, including those donated, should be tagged. This should not be limited to purchased technology equipment. Individuals responsible for tagging should be clearly identified and trained in these job duties. Tagging should be done in a timely manner to discourage theft. 4. All furniture, equipment and vehicle purchases should be added to the fixed asset inven- tory. All items declared surplus and disposed of should be deducted from the fixed asset inventory. All inventory lists, including the surplus inventory list, should be maintained and periodically reviewed for accuracy and completeness. 5. Receiving procedures for textbooks and physical inventory items that are shipped directly to school sites should be developed and distributed. 6. An employee should be assigned to maintain the fixed asset inventory management system. All individuals involved in asset identification, reporting and tagging should be properly trained. Staff should be cross-trained in tagging procedures and database management. 356 Financial Management 7. The auditor recommendations for compliance with internal controls for inventory, fixed assets and disposal of assets should be implemented. 8. School sites and departments should use and properly complete the Salvage Inventory Sheet to document obsolete inventory as well as lost or stolen items; the completed form should be sent to the district office and should be used to support items sold to salvage or otherwise disposed of and to support deletions to the fixed asset list. 9. The draft Purchasing Department SOP and district salvage procedures should be updated to provide staff with comprehensive guidance regarding surplus assets and instructional materials. Focus should be placed on returning funds to any categorical sources that pro- cured the asset in accordance with EC and federal requirements. 10. District management, sites and staff involved with the disposition of district surplus items should be trained in the execution of AR 3270, the EC and the best practices as it relates to the chain of custody regarding salvage policies and procedures. 11. The processing and disposal of surplus assets and instructional materials should be cen- tralized. District-approved disposal firms should have their agreement and terms ap- proved by the county administrator/board prior to disposal of district assets. Only firms approved by the county administrator/board should be used since it was reported that some firms have paid cash for surplus items in the past. 12. The final disposal of all assets, including vehicles, should be documented. All surplus ve- hicles should be disposed of by a district office staff member who is knowledgeable of ARs regarding the disposal of fixed assets. 13. All vehicle pink slips should be secured at the district office. 14. Individuals performing textbook inventory control and asset tagging should be cross- trained so that the functions can be performed in their absence. 15. Textbooks from the district’s centralized inventory should be offered to sites prior to pur- chasing new items. Sites should have access to the online textbook inventory system. 16. County administrator/board action declaring instructional materials obsolete should pre- clude any disposal. Safeguards related to the disposal of surplus or undistributed obsolete instructional materials should be implemented, and the district should ensure that staff reconcile the items sold/recycled/taken to the dump with those the county administrator/ board approved for surplus. Financial Management 357 Standard Not Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 1 July 2017 Rating: 0 July 2018 Rating: 0 July 2019 Rating: 0 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 0 July 2022 Rating: 0 July 2023 Rating: 0 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 358 Financial Management 17.1 Food Service Fiscal Controls Professional Standard To accurately record transactions and ensure the accuracy of financial statements for the cafeteria fund in accordance with GAAP, the LEA has purchasing and warehousing procedures to ensure that these requirements are met. Findings 1. Unaudited actuals for the 2021-22 fiscal year show that the ending balance in the cafeteria fund increased from $1.8 million to $3.0 million. However, the 2021-22 audit report included various adjustments to deposits and investments, accounts receivable, other current assets, and accounts payable. These totaled a negative $1,166,154 and reduced the cafeteria fund balance to $1,832,111. 2. As shown in the table below, the cafeteria fund balance had been decreasing since 2018-19. However, after accounting for the 2021-22 audit adjustments, income outpaced expenditures slightly in 2021-22. Correspondence from the CDE, dated September 19, 2022, indicated that the state increased the Net Cash Resources limit from three to six months of expenditures, and because the district did not exceed the new limit, the spend- down agreement was no longer needed. Cafeteria Fund-Unaudited Actuals, 2016-17 through 2021-22 Unaudited Actuals 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 Beginning Balance $1,505,126 $2,342,779 $2,952,292 $2,910,705 $2,106,512 $1.816,750 Adjustments/Restatements $363,321 $198,806 $49,287 $0 $389,820** $0 Adjusted Beginning Balance $1,868,447 $2,541,585 $3,001,579 $2,910,705 $2,496,332 $1,816,750 Revenues $4,877,680 $4,391,398 $4,275,759 $3,199,035* $2,057,750 $5,757,775* Expenditures ($4,403,348) ($3,980,692) ($4,366,633) ($4,003,228) ($2,737,332) ($4,576,260) Ending Balance $2,342,779 $2,952,292 $2,910,705 $2,106,512 $1,816,750 $2,998,265*** * Includes general fund transfer of $245,134 in 2019-20 and $43,046 in 2021-22 ** Includes an audit adjustment of $388,614 and a restatement of $1,206 ***As of the 2022-23 first interim reporting period, the district had not posted the 2021-22 audit adjustments of negative $1,166,154 3. The cafeteria fund’s accounts payable balances have continued to decrease since June 2018. The unaudited accounts payable balance as of June 2022 was $201,294. However, the 2021-22 audit report showed the district overstated accounts payable by $21,031 at year-end close, so the audited ending fund balance was increased by this amount. The cafeteria fund’s accounts receivable balances in prior years had remained high, with an accrual of $1,135,639 as of June 2019. Although the balances were reduced in 2019- 20 and 2020-21, the unaudited accounts receivable balance as of June 2022 was $1,272,667. However, the 2021-22 audit report showed the district overstated accounts receivable by $1,267,553, so the audited ending fund balance was decreased by this amount. Financial Management 359 4. The 2022-23 first interim report shows that the district budgeted 5.43% rather than the maximum allowable indirect cost rate of 5.35% in the cafeteria fund. 5. The June 22, 2022 board meeting included approval of the district’s membership in a purchasing cooperative for frozen, refrigerated, processed commodity and/or commercial food products. The June 29, 2022 board meeting included approval of agreements pursuant to a request for proposal for paper products. Various board meetings for this review period included amendments and renewals to bids for pizza and dairy products, as well as approval to participate in a piggyback bid for equipment and supplies. Interviews indicated that due to the district’s relatively small size, it continues to pursue and use piggyback bids from other school districts to purchase some food service products. 6. Interviews indicated time certifications for employees who are paid with federal food service funds are maintained. Although FCMAT requested the completed time certifications, none were provided. 7. During this review period, interviews indicated that staff have started to prepare profit and loss and meals-per-labor-hour reports. Although these documents were requested, they were not provided to FCMAT. Maintaining monthly financial reports, such as meals per labor hour and profit and loss statements, would provide management with a way to more quickly identify variances in income and expenses, determine the ongoing impacts, and implement any necessary remedies. 8. As stated in Standard 10.4, the BEST accounts payable system can use individual invoice numbers to check for duplicate payments. Interviews indicated that individual vendor invoices are not entered in the accounting system for all food service vendors. Some vendor invoices are batch processed, and payments are made based on summary statements. This does not allow the computer system to monitor for duplicate invoices. If using a batch system, manual internal controls must be added to reduce opportunities for duplicate payments. During this review period, staff indicated the invoice numbers continue to be entered on an Excel spreadsheet to determine if there are any duplicates. 9. During the prior review period, the district hired a director of fiscal services whose duties included oversight of food service, along with the two food service operations managers. During this review period, the district restructured the Food Services Department and promoted one of the operations managers to director of food services on June 27, 2022. The resulting vacant operations manager position was filled on August 8, 2022. The department’s accounting specialist retired in August 2022, and the position was replaced by a six-hour per day accounting assistant in December 2022. 10. With the restructuring, the district will need to continue efforts to ensure adequate staff training, including training for budget development and monitoring, the direct certification process, and how best to work with district office staff to ensure the implementation of the Community Eligibility Provision and the universal free meals program does not negatively impact the UPC and LCFF funding. Training should also be provided to ensure financial and compliance reporting are done accurately and in a timely manner. 360 Financial Management 11. Bank reconciliation spreadsheets provided to FCMAT showed that staff perform a monthly reconciliation of the food service clearing account. The reconciliations included the preparer’s name but not the date of preparation, so it is unknown if they were completed timely. The reconciliations were not signed and dated by a secondary reviewer, so it is unknown if the work was reviewed. In addition, bank statements were requested but not provided; therefore, FCMAT could not compare the reconciliations to the statements for accuracy. 12. During the prior review period, the January 5, 2022 Petty Cash Reconciliation provided to FCMAT did not show any transactions, and staff indicated that petty cash had not been used during the pandemic. Staff indicated that petty cash has still not been used during the current review period. 13. Interviews indicated that the Food Services Department is responsible for tagging its own fixed assets. The tags are received from the warehouse, and food service staff maintain equipment inventory lists by school site; however, staff do not know how food service assets that are newly purchased, moved, or disposed of are updated on the main district asset list. FCMAT requested the inventory for the district’s food service commodities, but it was not provided. Recommendations for Recovery 1. The district should continue to monitor the cafeteria fund Net Cash Resources calculation to ensure that the state limit is not exceeded. 2. The district should ensure that food service management staff is knowledgeable about program requirements, including the state’s Administrative Review process. 3. The district should ensure that year-end accounts receivable and accounts payable balances are supported with detailed transaction documentation that includes vendor/ payee and amount. All items should be reviewed and cleared by the first interim reporting period. 4. The district office should review all the balance sheet items of the cafeteria fund as part of financial closing. Any unusual balances should be investigated. 5. Audit adjustments recommended by the independent auditor should be posted in a timely and accurate manner. 6. The district should budget and charge the full allowable indirect cost rate, but no more, to the cafeteria fund. 7. The district should ensure staff is trained on the proper procurement processes and regulations – including Federal Acquisition Regulations when using federal funds – necessary to seek bids, requests for proposals, and requests for quotes to make sure it obtains the best prices available. Financial Management 361 8. The district should follow requirements for federal time reporting for all employees who are paid from federally funded programs and ensure certification forms are properly completed. 9. The district should ensure that food service management staff properly analyze the financial aspects of the food service program monthly and perform the basic calculations necessary to analyze profitability and identify areas of concern. 10. If a batch system is used to enter vendor invoices in the accounting system, manual internal controls should continue to be used to replace the BEST controls to reduce opportunities for duplicate payments. 11. The district should continue to be vigilant and support efforts to ensure adequate training for food service staff. 12. Bank accounts should be timely and accurately reconciled, and the work should be signed and dated by the preparer, and it should be reviewed, signed, and dated by a supervisor monthly. Variances, stale-dated checks and lingering deposits in transit should be investigated and addressed in a timely manner. 13. If the Food Services Department uses the petty cash fund, it should maintain logs with supporting documentation and authorization for all expenses charged to petty cash. 14. The district should centralize all purchasing, bidding, tagging and salvage procedures. This would centralize knowledge, standardize procedures and increase accountability. 15. Funds received for the disposal of surplus items that were purchased with food service funds should be deposited in the cafeteria fund. 16. The district should ensure that an inventory of its food service commodities is properly maintained. 362 Financial Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 2 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Financial Management 363 20.1 Special Education Professional Standard The LEA actively takes measures to contain the cost of special education services while providing an appropriate level of quality instructional and pupil services to special education students. The LEA meets the criteria for the maintenance of effort requirement. Findings 1. Effective with the 2017-18 school year, the Southwest SELPA transferred administrative and program responsibilities from LACOE to Lawndale Elementary School District. As of fiscal year 2018-19, the Southwest SELPA is responsible for supervising all special education programs and coordinating regionalized services between all member districts, and LACOE no longer provides regionalized services to the district. As part of the program takeback, the member districts voted to partially support the regionalized services costs for three years with a SELPA subsidy. The procedure states that the subsidy will be prorated between special day class/related services and itinerant costs, based on the proportion of each cost group to the total of all costs, ultimately reducing the amounts the district paid for regionalized services. The allocated subsidy amounts were $8 million in both 2018-19 and 2019-20 and were reduced to $4 million in 2020- 21. Beginning with fiscal year 2021-22 the SELPA did not supplement the regionalized services program. The district’s 2021-22 final billing for regionalized services was $1.47 million, which includes a reduction of $619,484 for various revenue offsets. FCMAT did not receive supporting documentation regarding the district’s estimated costs for the 2022- 23 regionalized services program. 2. The district still contracts with outside agencies for all speech-related services including assessment, progress monitoring and IEP participation; however, now the district meets monthly with the agencies. A district program specialist participates in all IEPs, so agencies are not exclusively managing these services provided to students. As mentioned in previous reports, using an outside agency to assess students, determine the level of service students need and provide speech services can create a conflict of interest and is not a best practice. 3. The district filed four claims for reimbursement related to the extraordinary cost pool for students who attended an NPS/LCI in fiscal year 2021-22. According to LACOE Bulletin 6582, extraordinary cost pool claims are now filed using the CDE’s Principal Apportionment and Data Collection software. Each claim submitted must be signed by the district’s SELPA director and include copies of all paid invoices and warrants and other documentation to support the claim. Costs for a single placement in excess of the annual threshold amount eligible for reimbursement should include tuition and all other costs for services not excluded in EC 56836.20. The threshold amount for 2021-22 was $84,933.06. The district provided backup documentation to FCMAT in support of the four reimbursement claims filed for 2021-22. 364 Financial Management 4. According to interviews, the district is using the shared email account between the Special Education and Business Services departments to ensure that both departments receive all NPA/NPS invoices. The Special Education Department staff has created a spreadsheet that tracks NPA and NPS expenditures for each vendor and student by month. To simplify the extraordinary cost pool expenditure tracking, the district should track the NPA and NPS expenditures separately. Each student’s expenses and eligibility should also be closely monitored to ensure documentation is sent to the SELPA by the required deadline for all eligible students who exceed the 2022-23 threshold of $90,504.67. 5. The SELPA reimburses LEAs based on the number of all eligible students receiving related mental health services. The SELPA also reimburses a portion of the costs of students in residential treatment centers. To maximize mental health funding allocated by the SELPA, it is imperative that all mental health expenditures be identified, documented and reported to the SELPA. It is also important that billings from the NPS show mental health charges separately, and that payments be split funded with mental health and counseling expenses coded separately so the district can properly document expenditures and receive reimbursement. The district did not provide documentation showing mental health expenses are tracked and coded separately. 6. The district did not provide FCMAT with the latest SELPA Regional Excess Cost document. This document provides the district with the preliminary regional program cost amounts, which get updated at various times throughout the fiscal year. Since no documentation was provided, FCMAT could not verify if the amount included in the district’s 2022-23 first interim report matched the amount estimated by the SELPA. Because this cost estimate can fluctuate throughout the year as the SELPA updates it, the district should closely monitor its budgeted expenditure projection to ensure it is not overstating or understating the amount. 7. As stated in letters from the county office in response to the district’s financial reports, the county continues to be concerned about the year-over-year increased financial strain that the special education program expenditures have on the unrestricted general fund. 8. Interviews indicated that the district is considering adding additional staff in the Special Education Department. Proposed changes that would further increase expenditures are concerning given the continued increased cost of the district’s special education program. As stated previously and in the prior year report, FCMAT is concerned with any proposed changes that would increase expenditures in an operational area that the district should be analyzing for improved efficiencies. 9. As stated earlier, the district has taken some steps to encourage communication between the Business Services and Special Education departments regarding NPA/NPS concerns. Interviews indicated that administrators from both departments were meeting weekly to discuss the SELPA’s excess cost billings and review the budget. Interviews indicated that due to the turnover in staff communication has become difficult, especially due to the steep learning curve of the new staff. As recommended in the past, communication should be occurring to discuss topics such as: budget development and monitoring, maintenance- Financial Management 365 of-effort requirements, additional staff requests or change in assignments, NPA/NPS contracts and invoices, due process and complaint issues, staff caseloads, identified student counts, and identified program needs. To provide for consistent data districtwide, the HR Department should be included when meeting topics involve staffing issues. 10. Maintenance-of-effort documentation provided to FCMAT indicates that the district’s 2021-22 unaudited actuals unrestricted general fund contribution to special education programs (including special education transportation) was $23.0 million or 67.80% of total special education expenditures; the 2020-21 unaudited actuals contribution was $22.8 million or 80.51%. The statewide average unrestricted general fund contribution to special education was 64.44% for 2020-21 and 64.3% for 2021-22. Recommendations for Recovery 1. The district should monitor and conservatively budget for regionalized services excess costs. Since the SELPA eliminated the excess cost subsidy, the budget and MYFP projections should be adjusted as needed for increased excess costs. When 2022-23 is billed, a reasonableness analysis should be performed, and major variances should be investigated. 2. The district should continue to investigate plans for delivery of speech and language services to reduce reliance on outside providers. The district should ensure that assessments are done by a different provider than the provider of service. 3. The district should continue to ensure that there is always a representative from the district at IEPs where assessment results for speech and language services from outside agencies are discussed. 4. The costs for students who may qualify for special education extraordinary cost pool reimbursements should continue to be monitored and tracked. Reimbursement claims should be submitted timely and should be reviewed to ensure that all qualified students are reported. The executive director of special education should review and approve the filing. 5. Communication between the Special Education and Business Services departments should be formalized so that appropriate amounts are budgeted each year. The district should implement a working group to resolve any data inconsistencies between the Special Education, HR and Business Services departments. 6. The special education budget should be reviewed and updated after the completion of the prior year unaudited actuals in September and again before completion of the first and second interim reports and for estimated actuals. 366 Financial Management 7. The fiscal impact of program transfers should be evaluated prior to implementation. In addition, the business office should communicate with the SELPA so that the full impact of decisions to become a SELPA-provider district is understood prior to implementation. 8. The district should ensure it captures and reports all reimbursable mental health expenses incurred before developing additional services that appropriately expend local mental health funds. 9. The district should regularly review NPS billings to determine where expenses can be reduced and what mental health expenses should be charged against mental health funding. 10. The county administrator should continue to attend all the monthly SELPA superintendents’ council meetings because this position is the voting member representative for the district. The business office should continue to work with the Special Education Department to review the SELPA funding projections to ensure the accuracy of all funding calculations, and the physical receipt of funding. The business office should then follow up on any discrepancies between budgeted income and actual income received. 11. The CBO or designee in the business office responsible for the special education budget should continue to attend SELPA business meetings, particularly when the funding model is discussed and/or modified. If the district designates someone other than the CBO, the designee should communicate relevant information to the CBO after each meeting. 12. The district should continue to monitor its unrestricted general fund contribution to special education. 13. The Special Education Department should be involved in budget development and receive a copy of the special education budgets and staffing lists several times a year and prior to year-end. The Business Services and Special Education departments should review these documents and update them accordingly and should meet regularly to discuss the budget and other relevant topics. 14. District staff should generate expenditure and income trend data and analyze it compared to data from comparable districts to support informed discussion and program management. 15. A reasonableness review and analysis of variances should be performed before the submission of any special education budget, interim reports, and the maintenance of effort. Variances should be investigated before finalizing the report. 16. Prior to restructuring the Special Education Department, the district should compare the department’s organizational structure and staffing to that of several districts of similar size and student demographics. Changes that would further increase ongoing expenditures should be avoided. Financial Management 367 17. The number and costs of due process filings should be tracked and reviewed to identify areas of potential risk and to contain the cost of such filings. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 0 July 2017 Rating: 0 July 2018 Rating: 0 July 2019 Rating: 0 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 0 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 368 Financial Management 21.1 Transportation Professional Standard The LEA actively takes measures to control the cost of transportation services and limit the con- tribution from the general fund while providing safe and reliable transportation to the students. Findings 1. Although the district provides most of its own special education student transportation, staff reported that LACOE transports some students because of a lack of capacity. The district ratified an agreement with LACOE for regional school transportation services (RSTS) for special education students from September 1, 2022 through August 31, 2023 during the September 14, 2022 board meeting, with a not-to-exceed amount of $890,000. An amendment to the original contract was approved on December 14, 2022, which increased the contract by an additional $895,000, for a new not-to-exceed amount of $1,785,000. According to the revised contract from LACOE and based on interviews with district staff, the increase was needed due to an increase in ridership. At the time of FCMAT’s fieldwork, the district did not provide LACOE transportation invoices or the supporting documentation, which includes a list of students. FCMATs review of the documents provided shows that expenses related to county contracted services are currently paid electronically through a journal voucher to LACOE monthly from object 5811; however, the district has budgeted for this expenditure under another object code. 2. The district also used transportation services from other vendors not related to special education. FCMAT found three contracts for student transportation services on the board agendas, and four other transportation vendors were paid from purchase orders for various amounts. Each contract and purchase order exceeded the $10,000 bid threshold for contracts for the transportation of pupils to and from school per EC 39802. In addition, the district’s purchasing policies require competitive bidding for purchases more than $10,000. 3. The Annual Report of Pupil Transportation previously filed with the state is no longer required beginning with the 2013-14 fiscal year. This report required the Transportation and Business Services departments to review year-end data and calculate the cost per mile for home-to-school transportation, the number of students transported, the cost per pupil, the number of buses and other statistics. Without this report, these departments will need to mutually determine the management data and information necessary to properly manage the Transportation Department expenses. As with previous years, no management reports or statistics were available for FCMAT’s review. 4. Transportation other than from home-to-school is referred to as “Other Miles,” which includes field trips, athletic events, summer school and trips between school sites (see CSAM Procedure 325 and 640 for further information). Costs for “Other Miles” are considered instructional costs to the user program, and although initially expensed to the Financial Management 369 transportation function, should be transferred (with supporting documentation) to other functions to offset the expenditures from the home-to-school transportation function. The district field trip rate charged to groups for school bus transportation was set several years ago at $360 for five hours. This rate appears to be arbitrarily set and may not accurately reflect the actual share of operating field trip transportation. It would benefit the district to ensure that the fees charged cover no less than the direct costs of the field trip and groups are not overcharged or undercharged. 5. Interviews with business office staff indicated that field trip requisitions are entered in the Informed K12 system by sites and departments, using a designated account code. After each field trip the Transportation Department notifies the business office accounting specialist that the field trip is complete and that it is okay to bill the appropriate site or department. FCMAT’s review of the documents provided shows that journal entries for field trips were processed in 2021-22; however, no journal entries had been processed through January 2023 in 2022-23. FCMAT’s review of the general ledger and budget reports shows that object code 5811 has been designated for field trips; however, vendors that provide transportation services unrelated to field trips are also paid from this object code. 6. Districts receive the same amount of funding for home-to-school pupil transportation that they were entitled to prior to the implementation of the LCFF in 2013-14. Under LCFF, the transportation revenues have never received a COLA and are subject to a maintenance of effort that requires districts to spend the lesser of the actual 2012-13 expenditures or the amount received in 2013-14. The district could not provide documentation to demonstrate that it was monitoring the maintenance of effort requirements. However, according to FCMAT’s review of the district’s financial reports, the district is spending significantly more than its entitlement. Per the 2021-22 unaudited actuals, the district spent approximately $2.6 million, and its entitlement is $962,143. The 2022-23 enacted state budget includes a COLA on the LCFF home-to-school transportation funding add-on beginning in 2023-24. 7. The 2022-23 enacted state budget provided for more than $630 million in additional ongoing funding as reimbursement to school districts based on prior year eligible home- to-school transportation expenditures. This additional funding will increase the district’s LCFF transportation entitlement to cover up to 60% of total transportation costs, less the LCFF home-to-school transportation add-on, provided the district complies with certain requirements. Specifically, the district must develop, and the county administrator must adopt, a transportation service plan on or before April 1, 2023 that describes how the district will offer transportation services to its students and how it will prioritize services for grades TK-6 and low-income students. The plan must be updated each year by April 1. EC 39800.1 outlines the plan’s required components, including the following: a. Description of the district’s transportation services that are accessible to students with disabilities and homeless youth. b. Description of how unduplicated pupils, or students identified as English learners, socioeconomically disadvantaged, and foster youth, will access available services at no cost. 370 Financial Management 8. FCMATs review of the actual expenditures reported for general education home-to-school transportation in fiscal year 2021-22 shows that the district spent just under one million dollars and is projected to spend approximately $700,000 in 2022-23. This is inconsistent with the information received during interviews that the district provides transportation only to its special education students, which it allocated separately to the special education transportation program. District staff should review and evaluate all transportation expenditures to ensure they are being properly allocated between general education home-to-school transportation and special education transportation. 9. Expenses should be properly coded to the respective transportation programs using a reasonable methodology. Based on information provided in interviews, the district transports only special education students. However, the monthly SC Fuels bill in fiscal year 2021-22 was expensed 50% to special education and 50% to home-to-school transportation. Although the district adjusted the split in 2022-23 to 80% special education and 20% to home-to-school transportation, the SC Fuels bill’s split does not appear to be distributed using a reasonable methodology. Additionally, FCMAT’s review of the position control report and interviews indicated that personnel charged to transportation are actually working in other departments. It is imperative for information to be consistent and reliable to adequately report and control the cost of student transportation. 10. The district continues to operate special education routes using many modes of transportation service including reimbursing parents for mileage to bring their student to school, passenger vans, taxis, independent contractors, and county office transportation services. While the district should attempt to transport students using the most cost- effective mode, the deputy chief maintenance and operations officer should be a resource in determining this mode. Budget accuracy could be improved if the Transportation Department managed all transportation contracts since personnel there have knowledge of issues such as vehicle maintenance, insurance requirements, DMV pull notices and fingerprinting regulations, and appropriate contracts to support the safe transport of students. Previous interviews with special education administration indicated that they were unaware of the PCC and EC 39802 requirements for procuring bids for transportation services that exceed $10,000 (see Standard 10.5). 11. In its prior reports, FCMAT recommended that the district ensure the student information contained on various student lists remain consistent with the actual number of severely disabled and orthopedically impaired (SD/OI) students transported, and that this information should be verified against student IEPs accordingly. During the 2015 review period, the special education staff reported that student names were reconciled with students enrolled and transported by LACOE. However, since that review period, there is inadequate evidence that the LACOE transportation billings are reconciled to the student roster. Since the district did not provide copies of the various invoices, FCMAT could not confirm if an authorized signature from the Transportation or Special Education departments for payment were notated. The district’s inability to provide the invoices also suggests that neither department is reviewing to ensure that all data is consistent and accurate. Financial Management 371 12. A review of the 2021-22 financial reports indicates that all LACOE transportation expenses are now charged directly to special education in resource code 92400, where they have been comingled with other contracted transportation services. The district’s adopted budget for special education transportation contracted services was $536,650, but at year-end actual expenditures were $760,850, which is more than what the district had budgeted. Although the district processed a budget adjustment on June 30, 2022 to increase the budget, possibly due to the negative remaining balance, the district should be monitoring its expenditures monthly and making budget adjustments as needed throughout the year. 13. The district continues to use the SC Fuels Fleet Card system, allowing drivers access to unattended automated commercial fueling stations 24 hours a day through a card-lock system. The system provides detailed logs that include the date and time of purchase; individual driver and vehicle number; as well as the type of fuel, the number of gallons pumped and the location of the station. As previously reported, the district does not reconcile detailed statement information that is provided with the SC Fuels Fleet Card system. For example, although cards were assigned to a particular vehicle and not a specific driver, the statements showed that a vehicle was filled with diesel fuel on some days and with gasoline on others. In addition, the odometer readings entered by several individuals fluctuated up and down and were inconsistent over multiple months for multiple vehicles. If odometer recordings were consistent, a reasonableness check could be performed to determine if vehicle fuel usage is accurate. 14. Interviews indicated that district staff recently reviewed all names associated with district supplied SC fuel credit cards. All previous fuel cards have been canceled, and new ones have been reissued by driver name with a unique personal identification number (PIN) that is not to be shared. Additionally, the business office has recently implemented a new process for anyone using a district fuel card. These employees are now required to complete a reconciliation form and attach the receipts to the signed invoice. This process was newly adopted, and FCMAT was not provided with supporting documentation to verify compliance. Recommendations for Recovery 1. The district should develop processes and procedures to ensure that information on the num- ber of students transported and the means used to transport them is consistent and reliable. 2. The district should regularly charge the cost of field trips to individual programs and ensure the expenses are posted timely. Staff should ensure that all expenses are charged to the correct object and function codes. 3. The district should communicate any account code changes to the county controller’s office to ensure that transportation invoices are charged to the account where the expense is budgeted. 4. The Transportation and Special Education departments should evaluate the costs of trans- portation provided by the county office, NPS and transportation service companies to determine whether the district can transport these students more cost effectively. 372 Financial Management 5. The district should review, approve and reconcile all transportation billings. The Special Education and Transportation departments should both review and approve all invoices to ensure that all district data is consistent with the actual number of SD/OI and RSTS students enrolled and transported. 6. To manage transportation expenses, the Transportation Department should regularly have access to its budgets and expenses. Transportation budgets, including those for expenses related to county and independent contractor provided services, should be reviewed for reasonableness and invoices should be reviewed and approved prior to payment. 7. The district should train staff to code transportation expenditures consistently and cor- rectly. 8. The district should ensure the transportation maintenance-of-effort expenditure level is maintained based on the requirements of LCFF. 9. The district should request that detailed log information from its fuel vendors be forwarded to the business office and Transportation Department monthly. Individuals should not ap- prove their own fuel expenditures. Employees who use fuel cards should receive training and be required to sign off on receipt of fuel card policies/procedures. The district should con- tinue to have fuel cards issued to individual drivers with his or her name and a unique PIN and should not allow for any cards to be shared. Information received from the third-party logs should be regularly analyzed and reviewed with anomalies investigated. 10. Expenses for transportation costs should be properly budgeted and expensed to the cor- rect cost center accounts to facilitate analysis and ensure that all expenses are accounted for in the adopted budget. Student transportation expenses should be allocated correctly between general education and special education transportation budgets. 11. The Transportation Department should monitor and manage all contracts and costs re- lated to special education transportation. 12. The district should ensure that its Transportation Department is staffed appropriately. 13. To reduce costs, an individual from the Transportation Department should be consulted in each IEP and advised of all contracts to provide student transportation. The Transpor- tation Department should review all contracts for special education transportation ser- vices prior to county administrator/board approval. 14. The district should ensure that transportation services are procured in accordance with PCC and EC requirements. 15. No transportation of district students by a contractor should occur until a fully executed contract is in place. 16. The district should review transportation costs and prepare a trend analysis to isolate vari- ances in expenditure categories. Financial Management 373 17. The district should compile and analyze the necessary data and identify the cost of any program or delivery method modifications that may affect its transportation program, ensuring that it will reduce costs and/or generate income. 18. The district should evaluate the rate charged for field trips to ensure it is sufficient to cover costs but avoid overcharging for the services. 19. The district should review new home-to-school transportation reimbursement require- ments, and prepare and adopt a transportation services plan by April 1, 2023 and update the plan by April 1 each year thereafter so it can access additional home-to-school trans- portation program funds. 20. The district should account for costs of various transportation activities that are not part of the home-to-school transportation activities and transfer to the benefiting function based on supporting documentation. Standard Not Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 0 July 2018 Rating: 0 July 2019 Rating: 0 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 0 July 2022 Rating: 0 July 2023 Rating: 0 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 374 Financial Management 22.1 Risk Management – Other Post-Employment Benefits Legal Standard LEAs that provide health and welfare benefits for employees upon their retirement, and those benefits will continue past the age of 65, shall provide the board an annual report of actual accrued but un- funded costs of those benefits. An actuarial report should be performed every three years. (EC 42140) Findings 1. GASB 74 (applicable only for prefunded plans with irrevocable trusts) and GASB 75 (employer accounting), replaced GASB 43 and 45 in June 2015. Statement No. 74 is not applicable to the district because it does not have an irrevocable trust. GASB 75, Account- ing and Financial Reporting for Postemployment Benefits Other Than Pensions, is effec- tive for plan years beginning after June 15, 2017, and requires employers to update OPEB actuarial reports every two years. The purpose of Statement No. 75 is to improve financial reporting requirements for local governmental employers and present a more realistic unfunded OPEB liability on the balance sheet of governmental financial statements. Governmentwide financial statements must now include the total liability related to OPEB. The district continues to comply with the requirements of GASB 75. The most recent actuarial report prepared for the district was dated August 30, 2022. The valuation report covers the district’s OPEB liability as of July 1, 2021. Plan membership as of July 1, 2021 includes 33 retirees and 842 active employees who may attain eligibility for benefits in the future. The updated report was presented to the county administrator/board at its September 14, 2022 meeting. The Schedule of Changes in Total OPEB Liability supplemental schedule dated August 30, 2022, provides for the following updates: Total OPEB Liability–June 30, 2020 (July 1, 2019-June 30, 2020) $25,212,931 Total OPEB Liability–June 30, 2021 (July 1, 2020-June 30, 2021) $22,831,614 2. The district funds this OPEB liability using the pay-as-you-go method. For the 2022-23 fiscal year under this funding method, the district’s cost is $499,607. The following table also shows the incremental cost for each of the next four years, as indicated in the August 30, 2022, actuarial report. % Increase from Fiscal Year Pay-as-you-go the prior year 2022-23 $ 499,607 55.63% 2023-24 $ 624,575 25.01% 2024-25 $ 675,089 8.09% 2025-26 $ 750,823 11.22% 2026-27 $767,591 2.23% Financial Management 375 Based on the actuarial projection and method of payment, the district’s payment will in- crease each fiscal year, doubling by 2033-34 reaching a cost of $1,033,272. Recommendation for Recovery 1. The district should continue to ensure that a current actuarial report is prepared every two years, as required by GASB 75, that it is presented to the county administrator/board and that the increasing projected costs are appropriately accounted for in its budget and multiyear financial projections. Standard Fully Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 0 July 2018 Rating: 6 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 8 July 2022 Rating: 9 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 376 Financial Management 22.2 Risk Management – Other Post-Employment Benefits Professional Standard The LEA has a comprehensive risk management program that monitors the various aspects of risk-management including workers’ compensation, property and liability insurance, and main- tains the financial well being of the LEA. In response to GASB requirements, the LEA has com- pleted recent actuarial reports for workers’ compensation and property and liability. The actu- arial assumptions properly track to the LEA’s budget assumptions and include the benefits being provided under existing plans. Findings 1. The district is self-insured for its workers’ compensation program. Since July 1, 2013, Keenan & Associates (Keenan) administers the program on behalf of the district. Keenan provides many online training programs designed for safety and accident prevention, to assist school districts. The district uses a self-insurance fund (fund 67) to account for workers’ compensation activities. 2. The executive director of HR and risk management, who was responsible for oversight of the risk management program, resigned effective April 1, 2022. Another HR employee was reassigned as an interim from April 2022 to November 2022; in December 2022, the district hired an executive director of risk management, who reports to the CBO. Risk management responsibilities are now split between HR and Business Services. HR continues to oversee employee health benefits, and Business Services is responsible for workers’ compensation, property and liability insurance, and district safety programs. The district has also contracted with a consultant to support the new executive director in managing workers’ compensation activities. 3. The executive director of risk management maintains an online system of interactive workers’ compensation forms accessible to all district staff for reporting claim incidents. Claims processed through this online portal allow the district to comply with mandated timelines for reporting and creates an Occupational Safety and Health Administration log that identifies potential reportable issues. This system incorporates a medical release form and all necessary disclosure requirements. 4. The district contracts with a workers’ compensation clinic that provides an online portal to give the executive director of risk management immediate access to injury and work status. The district continues a transitional return-to-work program that allows injured workers the ability to return to work based on limitations prescribed by the clinic. The district continues using online safety trainings for professional development as well as injury prevention. 5. With the significant employee turnover during the review period, certain risk management functions were reassigned to other employees, but some activities ceased (e.g., the tracking of available leave categories and differential pay for industrial leaves). Financial Management 377 Interviews indicated that no one was monitoring leave data to ensure the appropriate reduction to individual payroll records, if necessary, resulting in possible employee overpayments. 6. The district contracted with Bickmore Actuarial to complete an updated workers’ compensation actuarial study. The report dated May 18, 2022 covered the period through April 30, 2022 and extrapolated to June 30, 2022. According to this report, the district’s estimated outstanding losses (cost of unpaid claims) is $14,889,506. The workers’ compensation actuarial study found that the present value of estimated outstanding losses as of June 30, 2022, is $13,466,650. The district maintains a self-insured retention of $650,000, which is projected to be maintained through 2022-23. Based on a self- insured retention of $650,000, the projected expected payroll loss rate is $5.317 per $100 of payroll and a present value loss rate of $4.792. Review of the district’s 2022-23 general fund budget indicates a rate of $4.400 per $100 of payroll has been budgeted for planning purposes. The actuarial report recommended funding rate is between $5.971 to $6.909 per $100 of payroll, at a 75% to 85% confidence level. The total assets retained by the district in the self-insurance fund (fund 67) as of June 30, 2022 were $13,824,412. The number of claims per $1 million of payroll steadily decreased from 2014-15 through 2017-18 from 1.95 to 1.11, and the average cost per claim increased from $14,211 to $19,750. In 2018-19, the trend shifted upwards with claims per $1 million of payroll increasing to 1.48, and the average cost per claim increasing to $28,466, but in 2019-20 and 2020-21, the trend returned to its downward trajectory falling to 0.71 and 0.40 per $1 million of payroll respectively; but the average cost per claim rose to a high of $53,440 in 2020-21. The Bickmore report shows the number of claims and losses reported from 2016- 17 to 2021-22 (as of April 30, 2022), as follows: Reported Reported Fiscal Year Claim Count Incurred Losses 2016-17 112 $2,405,807 2017-18 68 $1,537,284 2018-19 88 $3,434,622 2019-20 43 $1,774,114 2020-21 24 $782,791 2021-22 50 $1,166,748 During the 2021-22 fiscal year the district budgeted $6.125 million for workers’ compen- sation claims payments (it appears the district mistakenly processed a budget revision on June 30, 2022, which doubled the budget from $3.062 million) and incurred expenditures of approximately $2.518 million. The district’s 2022-23 budget has been adjusted to $3.1 million; as of December 2022 expenditures that exhaust approximately 48 percent of that budget have been recorded, but encumbrances and preencumbrances total $4.139 million resulting in a negative budget balance of $2.532 million. 7. The district budgeted $2.55 million for property and liability insurance premiums in 2021-22 (it appears the district mistakenly processed a budget revision on June 30, 2022, which doubled the budget from $1,275,000), but closed the fiscal year with $1,140,031 378 Financial Management in total expenditures. For the 2022-23 fiscal year, the district has budgeted $1.34 million. District staff indicated that the deductible of $1 million per claim remains unchanged. 8. Joint Powers Authority, Alliance of Schools for Cooperative Insurance Programs (ASCIP) has historically assisted the district with the coordination of school site safety and playground audits conducted by Poms & Associates. The district contracted with Poms & Associates through ASCIP to conduct a safety inspection at each school site between February 23 and March 21, 2017. A progress summary document prepared by Poms dated April 1, 2019, shows that there were 33 immediate and 176 high-level concerns. While some of the deficiencies noted in the 2019 progress report may have been mitigated through school site modernization and facility projects, no subsequent school site inspections have been conducted to determine progress. Recommendations for Recovery 1. The district should continue to monitor program implementation for online processing of forms for workers’ compensation claims, including information to managers and supervisors. 2. The district should ensure the executive director of risk management, HR and payroll staff meet regularly to resolve common issues related to employee leaves and differential pay. 3. The district should reinstate use of its interactive form to track leaves in accordance with EC provisions and bargaining unit language, and provide the necessary information to calculate leave data and the appropriate reduction to individual payroll records, if necessary. The executive director of risk management should continue to seek opportunities to automate systems in environments that are easily maintained and accessible to district personnel. 4. The district should closely evaluate the workers’ compensation rate applied against payroll and the asset balance held in the self-insurance fund to ensure the rate charged is sufficient to address estimated outstanding losses. 5. The district should review prior year actual expenditures and adjust current year budgets as necessary. Current year budgets should be reviewed and adjusted at least at interim reporting periods. 6. The district should continue to monitor timelines for required actuarial reports to ensure they are completed in a timely manner to avoid audit findings and ensure compliance with generally accepted accounting principles. 7. The district should provide timely safety assessments for all school sites and implement the resulting recommendations to correct hazardous conditions. Financial Management 379 Standard Partially Implemented July 2013 Rating: 4 July 2014 Rating: 4 July 2015 Rating: 0 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 5 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 380 Financial Management Table of Financial Management Ratings Financial Management 381 382 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – INTERNAL CONTROL ENVIRONMENT All board members and management personnel set the tone and establish the Omitted environment, exhibiting per SB 98, high integrity and ethical 1.1 values in carrying out 0 0 1 1 2 2 2 Section 2 2 2 102 due to their responsibilities COVID-19 and directing the pandemic. work of others. Appropriate measures are implemented to discourage and detect fraud. (Statement on Auditing Standards (SAS) 55, SAS 78, SAS 82: Treadway Commission) PROFESSIONAL STANDARD – INTERNAL CONTROL Omitted ENVIRONMENT per SB 98, The organizational 1.3 structure clearly identifies 1 0 3 4 4 5 6 Section 5 5 5 102 due to key areas of authority and COVID-19 responsibility. Reporting pandemic. lines in each area are clearly identified and logical. (SAS 55, SAS 78) PROFESSIONAL STANDARD – INTER- AND INTRADEPARTMENTAL COMMUNICATIONS The Business and Operational departments communicate regularly with internal staff and all user departments on Omitted their responsibilities for per SB 98, accounting procedures 2.1 and internal controls. 1 1 1 1 2 4 4 Section 4 4 4 102 due to Communications are COVID-19 written when they pandemic. affect many staff or user groups, are issues of importance, and/ or reflect a change in procedures. Procedures manuals are developed. The Business and Operational departments are responsive to user department needs. PROFESSIONAL STANDARD – INTER- AND INTRADEPARTMENTAL COMMUNICATIONS The board is engaged in understanding the fiscal status of the LEA, for the current and two Omitted subsequent fiscal years. per SB 98, 2.3 The board prioritizes LEA 0 0 1 3 4 5 6 Section 7 8 8 fiscal issues, and expects 102 due to reports to align the LEA’s COVID-19 financial performance with pandemic. its goals and objectives. Agenda items associated with business and fiscal issues are discussed at board meetings, with questions asked until understanding is reached prior to any action. Financial Management 383 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – STAFF PROFESSIONAL DEVELOPMENT The LEA has developed and uses a professional development plan for training business staff. Omitted The plan includes per SB 98, 3.1 the input of business 0 0 1 1 2 2 3 Section 3 4 4 office supervisors 102 due to and managers, and COVID-19 identifies appropriate pandemic. training programs. Each staff member and management employee has a plan designed to meet their individual professional development needs. PROFESSIONAL STANDARD – STAFF PROFESSIONAL DEVELOPMENT The LEA develops and uses a professional development plan for Omitted the in-service training of per SB 98, 3.2 school site/department 0 0 0 0 1 2 2 Section 2 3 3 staff by business staff 102 due to on relevant business COVID-19 procedures and internal pandemic. controls. The plan includes a process to seek input from the business office and the school sites/departments and is updated annually. PROFESSIONAL STANDARD – INTERNAL AUDIT Internal audit findings are Omitted reported on a timely basis per SB 98, 4.2 to the audit committee, 0 0 0 0 1 1 1 Section 1 2 1 board and administration, 102 due to as appropriate. COVID-19 Management then takes pandemic. timely action to follow up and resolve audit findings. PROFESSIONAL STANDARD – BUDGET DEVELOPMENT PROCESS The board focuses on expenditure standards and formulas that meet Omitted the goals and maintain per SB 98, 5.1 the LEA’s financial 1 0 0 1 1 3 4 Section 4 4 4 solvency for the current 102 due to and two subsequent COVID-19 fiscal years. The board pandemic. avoids specific line-item focus, but directs staff to design an entire expenditure plan focusing on student and LEA needs. 384 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – BUDGET DEVELOPMENT Omitted PROCESS per SB 98, 5.2 The budget development 1 0 1 1 1 2 4 Section 4 4 4 process includes input 102 due to from staff, administrators, COVID-19 board and community as pandemic. well as a budget advisory committee. PROFESSIONAL STANDARD – BUDGET DEVELOPMENT PROCESS The LEA has clear policies and processes to analyze resources and allocations to ensure that they align with strategic planning objectives and that the budget reflects the LEA’s priorities. The budget office has a technical process to build the preliminary budget that includes revenue and Omitted expenditure projections, per SB 98, 5.3 the identification of 0 1 3 2 2 3 4 Section 3 4 4 carryovers and accruals, 102 due to and any plans for COVID-19 expenditure reductions. pandemic. The LEA utilizes formulas for allocating funds to school sites and departments. This may include staffing ratios, supply allocations, etc. Standardized budget worksheets are used to communicate budget requests, budget allocations, formulas applied and guidelines. A budget calendar contains statutory due dates and major budget development milestones. LEGAL STANDARD – BUDGET ADOPTION, REPORTING, AND AUDITS The LEA adopts its annual budget within the statutory timelines established by EC 42103, Omitted which requires that on per SB 98, or before July 1, the 6.1 board shall hold a public 7 8 7 7 8 9 10 Section 10 10 10 102 due to hearing on the budget COVID-19 to be adopted for the pandemic. subsequent fiscal year. Not later than five days after that adoption or by July 1, whichever occurs first, the board shall file that budget with the county superintendent of schools. (EC 42127(a)) Financial Management 385 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating LEGAL STANDARD – BUDGET ADOPTION, REPORTING, AND AUDITS Revisions to expenditures based on the state budget are considered and adopted by the Omitted governing board. Not per SB 98, 6.2 later than 45 days after 0 0 5 7 8 9 10 Section 10 10 9 the governor signs the 102 due to annual Budget Act, the COVID-19 LEA shall make available pandemic. for public review any revisions in revenues and expenditures that it has made to its budget to reflect funding available by that Budget Act. (EC 42127(h)) LEGAL STANDARD – BUDGET ADOPTION, REPORTING, AND AUDITS The LEA completes and files its interim Omitted budget reports within per SB 98, 6.3 the statutory deadlines 2 2 5 5 6 6 7 Section 8 9 9 established by EC 102 due to 42130, et. seq. All reports COVID-19 are in a format or on pandemic. forms prescribed by the superintendent of public instruction and are based on standards and criteria for fiscal stability. PROFESSIONAL STANDARD – BUDGET MONITORING The LEA implements budget monitoring controls, such as periodic budget reports, to alert department and site Omitted managers of the potential per SB 98, 7.2 for overexpenditure 1 0 2 1 0 1 1 Section 1 2 2 of budgeted amounts. 102 due to Revenue and COVID-19 expenditures are forecast pandemic. and verified monthly. The LEA ensures that appropriate expenditures are charged against programs within the spending limitations authorized by the board. PROFESSIONAL STANDARD – BUDGET MONITORING The LEA uses an Omitted effective position control per SB 98, system that tracks 7.3 personnel allocations 1 0 4 4 3 4 4 Section 2 3 3 102 due to and expenditures. The COVID-19 position control system pandemic. establishes checks and balances between personnel decisions and budgeted appropriations. 386 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – ACCOUNTING The LEA forecasts Omitted its cash receipts and per SB 98, disbursements and 8.1 verifies those projections 1 3 4 3 2 4 4 Section 4 4 4 102 due to monthly to adequately COVID-19 manage its cash. The pandemic. LEA reconciles its cash to bank statements and reports from the county treasurer monthly. PROFESSIONAL STANDARD – ACCOUNTING The LEA’s payroll procedures comply with the requirements Omitted established by the county per SB 98, 8.2 office of education, 1 1 1 2 3 4 4 Section 3 4 4 unless the LEA is fiscally 102 due to independent. (EC 42646) COVID-19 Per standard accounting pandemic. practice, the LEA implements procedures to ensure timely and accurate payroll processing. PROFESSIONAL STANDARD – ATTENDANCE ACCOUNTING School sites maintain Omitted an accurate record per SB 98, 9.2 of daily enrollment 2 2 2 2 2 2 3 Section 4 5 4 and attendance that 102 due to is reconciled monthly. COVID-19 School sites maintain pandemic. statewide student identifiers and reconcile data required for state and federal reporting. PROFESSIONAL STANDARD – ATTENDANCE ACCOUNTING Omitted Policies and regulations per SB 98, 9.3 exist for independent 2 2 2 2 2 2 4 Section 6 7 6 study, charter school, 102 due to home study, inter-/intra- COVID-19 LEA agreements, LEAs pandemic. of choice, and ROC/P and adult education, and address fiscal impact. PROFESSIONAL STANDARD – Omitted ATTENDANCE per SB 98, ACCOUNTING 9.4 Students are enrolled 1 2 2 1 1 1 2 Section 3 4 3 102 due to and entered into the COVID-19 attendance system in an pandemic. efficient, accurate and timely manner. PROFESSIONAL STANDARD – ATTENDANCE Omitted ACCOUNTING per SB 98, The LEA utilizes 9.6 standardized and 2 1 4 4 4 3 2 Section 2 4 4 102 due to mandatory programs to COVID-19 improve the attendance pandemic. rate of pupils. Absences are aggressively followed up by LEA staff. Financial Management 387 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – ATTENDANCE Omitted ACCOUNTING per SB 98, School site personnel 9.7 receive periodic and 1 2 0 0 1 1 1 Section 1 3 4 102 due to timely training on the COVID-19 LEA’s attendance pandemic. procedures, system procedures and changes in laws and regulations. PROFESSIONAL STANDARD – ACCOUNTING, PURCHASING, AND WAREHOUSING The LEA timely and accurately records all financial activity for all programs. GAAP Omitted accounting work is per SB 98, 10.4 properly supervised 1 1 1 1 1 2 2 Section 2 2 2 and reviewed to ensure 102 due to that transactions are COVID-19 recorded timely and pandemic. accurately, and allow the preparation of periodic financial statements. The accounting system has an appropriate level of controls to prevent and detect errors and irregularities. PROFESSIONAL STANDARD – ACCOUNTING, PURCHASING, AND WAREHOUSING The LEA has adequate purchasing and Omitted warehousing procedures per SB 98, to ensure that: (1) only 10.5 properly authorized 1 1 0 1 1 1 2 Section 2 2 2 102 due to purchases are made, (2) COVID-19 authorized purchases are pandemic. made consistent with LEA policies and management direction, (3) inventories are safeguarded, and (4) purchases and inventories are timely and accurately recorded. LEGAL STANDARD – STUDENT BODY FUNDS The board adopts board policies, regulations and procedures to establish parameters on how student body Omitted organizations will be per SB 98, established, and how 11.1 they will be operated, 2 1 1 1 0 0 1 Section 1 2 2 102 due to audited and managed. COVID-19 These policies and pandemic. regulations are clearly developed and written to ensure compliance regarding how student body organizations deposit, invest, spend, and raise funds. (EC 48930-48938) 388 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating LEGAL STANDARD – STUDENT BODY FUNDS The LEA provides annual training and ongoing guidance to site and LEA personnel on the Omitted policies and procedures per SB 98, governing Associated 11.3 Student Body accounts. 1 1 0 0 0 1 1 Section 1 1 2 102 due to Internal controls are COVID-19 part of the training and pandemic. guidance, ensuring that any findings in the internal audits or independent annual audits are discussed and addressed so they do not recur. LEGAL STANDARD – MULTIYEAR FINANCIAL PROJECTIONS The LEA provides a multiyear financial projection for at least the general fund at a minimum, consistent with the policy of the county office. Projections are done for the general fund at the time of Omitted budget adoption and per SB 98, 12.1 all interim reports. 0 3 3 2 1 2 2 Section 1 4 2 Projected fund balance 102 due to reserves are disclosed COVID-19 and assumptions used pandemic. in developing multiyear projections that are based on the most accurate information available. The assumptions for revenues and expenditures are reasonable and supported by documentation. (EC 42131) LEGAL STANDARD – MULTIYEAR FINANCIAL PROJECTIONS The governing board ensures that any guideline developed for collective bargaining fiscally aligns with the LEA’s multiyear Omitted instructional and fiscal per SB 98, goals. Multiyear financial 12.2 projections are prepared 0 1 1 1 1 2 3 Section 2 2 1 102 due to for use in decision- COVID-19 making, especially pandemic. whenever a significant multiyear expenditure commitment is contemplated, including salary or employee benefit enhancements negotiated through the collective bargaining process. (EC 42142) Financial Management 389 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating LEGAL STANDARD – IMPACT OF COLLECTIVE BARGAINING Public disclosure Omitted requirements are per SB 98, 14.1 met, including the 0 0 4 6 7 7 6 Section 3 4 2 costs associated with 102 due to a tentative collective COVID-19 bargaining agreement pandemic. before it becomes binding on the LEA or county office of education. (GC 3547.5 (b)). LEGAL STANDARD – IMPACT OF COLLECTIVE BARGAINING Bargaining proposals and negotiated settlements Omitted are “sunshined” in per SB 98, 14.2 accordance with the 0 0 2 4 4 4 4 Section 4 4 2 law to allow public input 102 due to and understanding COVID-19 of employee cost pandemic. implications and, most importantly, the effects on the LEA’s students. (Government Code 3547, 3547.5) PROFESSIONAL STANDARD – IMPACT OF COLLECTIVE BARGAINING The LEA has developed parameters and guidelines for collective bargaining that ensure that the collective bargaining agreement does not impede the efficiency of LEA operations. Management analyzes the collective bargaining agreements to identify any characteristics that impede effective delivery Omitted of LEA services. The per SB 98, 14.3 LEA identifies those 0 0 2 3 5 7 7 Section 7 6 4 issues for consideration 102 due to by the governing board. COVID-19 The governing board, in pandemic. developing its guidelines for collective bargaining, considers the impact on LEA operations of current collective bargaining language, and proposes amendments to LEA language as appropriate to ensure effective and efficient service delivery. Governing Board parameters are provided in a confidential environment, reflective of the obligations of a closed executive board session. 390 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS Management information systems support users with information that is relevant, timely, and accurate. Assessments are performed to ensure Omitted that users are involved per SB 98, 15.2 in defining needs, 1 1 1 1 1 3 5 Section 4 5 4 developing specifications, 102 due to and selecting appropriate COVID-19 systems. LEA standards pandemic. are imposed to ensure the maintainability, compatibility, and supportability of the various systems. The LEA ensures that all systems are SACS-compliant, and are compatible with county systems with which they must interface. PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS Automated systems are used to improve accuracy, timeliness, and efficiency of financial and reporting systems. Needs assessments are performed to determine what systems are candidates for automation, whether standard hardware Omitted and software systems per SB 98, 15.3 are available to meet 3 3 4 3 3 4 4 Section 4 4 4 the need, and whether 102 due to or not the LEA would COVID-19 benefit. Automated pandemic. financial systems provide accurate, timely, relevant information and conform to all accounting standards. The systems are designed to serve all of the various users inside and outside the LEA. Employees receive appropriate training and supervision in system operation. Appropriate internal controls are instituted and reviewed periodically. Financial Management 391 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS Hardware and software purchases conform to existing technology standards. Standards for network equipment, servers, computers, copiers, printers, fax machines, and all other technology assets are Omitted defined and enforced to per SB 98, increase standardization 15.7 and decrease support 2 2 2 2 3 4 6 Section 5 5 6 102 due to costs. Requisitions COVID-19 that contain hardware pandemic. or software items are forwarded to the technology department for approval before being converted to purchase orders. Requisitions for nonstandard technology items are approved by the information management and Technology Department(s) unless the user is informed that LEA support for nonstandard items will not be available. PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS An updated inventory includes item specification for use in establishing standards for an equipment replacement cycle and rotating out obsolete Omitted equipment. Computers per SB 98, 15.8 and peripheral hardware 2 2 2 3 3 3 3 Section 2 2 2 are replaced based on 102 due to a schedule. Hardware COVID-19 specifications are pandemic. evaluated yearly. Corroborating data from work order or help desk system logs is used when this data is available to determine what equipment is most costly to own based on support issues. The total cost of ownership is considered in purchasing decisions. 392 Financial Management July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS In order to meet the requirements of both online learning and online student performance assessments, the district has documentation that provides adequate Omitted technology to per SB 98, support these needs. 15.10 Documentation should 2 6 4 6 7 8 9 Section 9 9 8 102 due to include sufficient COVID-19 bandwidth to each pandemic. school site, internal local network infrastructure capacity, electronic devices which meet the published minimum standards for online student assessments, and an adequate number of devices to allow testing of all students within the prescribed amount of time. PROFESSIONAL STANDARD – MANAGEMENT INFORMATION SYSTEMS The LEA optimizes funding of various types Omitted of technology throughout per SB 98, 15.11 the organization by 2 3 4 3 3 4 5 Section 6 6 7 effective utilization of 102 due to available Federal E-rate COVID-19 discounts, the California pandemic. Teleconnect fund, and other available discount programs and funding sources to reduce costs for various technology expenditures. LEGAL STANDARD – MAINTENANCE AND Omitted OPERATIONS FISCAL per SB 98, CONTROLS 16.1 Capital equipment and 1 0 0 1 0 0 0 Section 0 0 0 102 due to furniture is tagged as COVID-19 LEA-owned property pandemic. and inventoried at least annually. PROFESSIONAL STANDARD – FOOD SERVICE FISCAL CONTROLS To accurately record Omitted transactions and per SB 98, ensure the accuracy 17.1 of financial statements 1 0 0 0 2 3 3 Section 3 3 3 102 due to for the cafeteria fund in COVID-19 accordance with GAAP, pandemic. the LEA has purchasing and warehousing procedures to ensure that these requirements are met. Financial Management 393 July July July July July July July July July July July Financial Management 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Standards Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating Rating PROFESSIONAL STANDARD – SPECIAL EDUCATION The LEA actively takes measures to contain the Omitted cost of special education per SB 98, 20.1 services while providing 1 1 3 0 0 0 0 Section 0 2 2 an appropriate level of 102 due to quality instructional and COVID-19 pupil services to special pandemic. education students. The LEA meets the criteria for the maintenance of effort requirement. PROFESSIONAL STANDARD – TRANSPORTATION The LEA actively takes Omitted measures to control the per SB 98, 21.1 cost of transportation 2 2 1 1 0 0 0 Section 0 0 0 services and limit the 102 due to contribution from the COVID-19 general fund while pandemic. providing safe and reliable transportation to the students. LEGAL STANDARD – RISK MANAGEMENT – OTHER POST- EMPLOYMENT BENEFITS LEAs that provide health and welfare benefits for Omitted employees upon their per SB 98, 22.1 retirement, and those 0 0 0 0 0 6 7 Section 8 9 10 benefits will continue 102 due to past the age of 65, shall COVID-19 provide the board an pandemic. annual report of actual accrued but unfunded costs of those benefits. An actuarial report should be performed every three years. (EC 41240) PROFESSIONAL STANDARD – RISK MANAGEMENT – OTHER POST EMPLOYMENT BENEFITS The LEA has a comprehensive risk- management program that monitors the various aspects of risk management including Omitted workers’ compensation, per SB 98, 22.2 property and liability 4 4 0 2 3 5 6 Section 6 6 6 insurance, and maintains 102 due to the financial well being COVID-19 of the LEA. In response pandemic. to GASB requirements, the LEA has completed recent actuarial reports for workers’ compensation and property and liability. The actuarial assumptions properly track to the LEA’s budget assumptions and include the benefits being provided under existing plans. Collective Average Rating 1.19 1.33 1.95 2.16 2.44 3.28 3.81 — 3.70 4.26 4.00 394 Financial Management Facilities Management Facilities Management 395 396 Facilities Management 1.1 School Safety Legal Standard The LEA has adopted policies and regulations and implemented written plans describing proce- dures to be followed in case of emergency, in accordance with required regulations. All school ad- ministrators are conversant with these policies and procedures. (EC 32001-32290, 35295-35297, 46390-46392, 49505; GC 3100, 8607; CCR Title 5, Section 550, Section 560; Title 8, Section 3220; Title 19, Section 2400) Findings 1. The district last revised and adopted BP 0400-Comprehensive Plans on September 19, 2018. The district also revised and adopted BP and AR 0450-Comprehensive Safety Plan and BP and AR 3516-Emergency and Disaster Preparedness Plan on April 17, 2019, and AR 3516.3-Earthquake Emergency Procedure System on February 20, 2019. 2. AR 3516.1-Fire Drills, AR 3516.2-Bomb Threats and BP-3516.5 Emergency Schedules were last updated on August 4, 2014. 3. The district does not have a person designated as responsible for safety compliance. Such a designee could ensure that policies are current, plans are completed, training is provided, committees are working and drills occur. 4. The Comprehensive School Safety plans were available at each of the school sites. The plans were in the main office of each campus, but not all of them had been approved by their respective school site council and the county administrator/board. Links to the Comprehensive School Safety plans were also posted on the district website, but at the time of FCMAT’s visit, the links were not working. 5. Site surveys completed by the site administrators indicated all sites had conducted on-site earthquake and fire drills. Some surveys included the dates for the fire drills, and some sites indicated that the dates for the drills were included in their Comprehensive School Safety plans, but that information could not be verified by FCMAT because the website links to the individual site plans were not working. Records indicated that all school sites participated in the latest annual statewide Great California Shake Out Earthquake Drill on October 20, 2022. 6. Most of the school sites had current and complete emergency telephone number listings and evacuation route maps posted in administrative offices and all classrooms. Schools not 100% in compliance with evacuation maps and emergency telephone number information sheets included Bennett-Kew, Highland, Hudnall, Kelso, Payne, and Worthington elementary schools. FCMAT found some evacuation maps and emergency telephone numbers with outdated, missing, or incorrect information. Facilities Management 397 7. As identified in the prior review, the district no longer has an active District Safety Committee. According to documents provided and found on the district website, the last meeting held by the District Safety Committee was in February 2021. Some site principals indicated they had created school site safety committees at their respective schools and discussed the school site safety plans regularly. 8. Most school sites reported that their SSCs had approved their respective 2022-23 Comprehensive School Safety plans, but a few reported theirs had not been updated or approved for this review period. 9. The district now has a full-time chief of police who assists sites in updating the Comprehensive School Safety plans throughout the district. The chief indicated he has also provided some virtual safety training on lockdowns and fight protocols to SSCs and staff throughout the school year. 10. For this review period, no evidence was provided to support the district conducted any district-level or districtwide meetings that discussed the Comprehensive School Safety plans, which include overall districtwide emergency preparedness and procedures, in the past year. 11. The deputy chief maintenance and operations officer continues to provide key leadership in addressing facility related emergency and safety issues. Recommendations for Recovery 1. The district should regularly review board policies and administrative regulations and update as warranted to ensure they are still compliant, accurate and applicable. Administrative Regulations 3516.1, 3516.2 and Board Policy 3516.5, last updated in 2014 should be reviewed and updated if needed. The district should make record of the review even if updating is not needed. 2. The district should designate a district-level position that is responsible for coordinating safety compliance to include the relevant policies, plans, committees, trainings and drills. 3. The district should continue to annually review, update and approve the Comprehensive School Safety plans, and they should be made available for access, at a minimum, in each school site office and be posted on the district website. 4. The district should continue to perform regular fire and earthquake drills at each site and include the schedule for the drills in their respective Comprehensive School Safety Plan. The district should require all school sites to provide evidence ensuring fire drills are performed. 5. The district should regularly inspect all rooms where students or staff may be present to ensure they have posted accurate evacuation route maps and emergency telephone numbers. The information should be posted in a location where it can be easily seen by all students and staff members in an emergency, and all evacuation maps should clearly and accurately identify the route to be taken in an emergency. 398 Facilities Management 6. The district should consider reinstating the District Safety Committee for the development of districtwide safety and emergency planning. 7. All school sites should update and have their SSCs approve the Comprehensive School Safety plans for the current school year. The district should require evidence of compliance from each school site that SSC meeting agendas are posted, and minutes are recorded approving their safety plan. 8. The chief of police should continue to assist the district in its annual preparation of Comprehensive School Safety plans, as well as continue to provide training to site councils and staff in all facets of school safety processes and procedures. 9. The district should annually conduct district-level, or individual site-level, meetings, which discuss the Comprehensive School Safety plans that include districtwide emergency preparedness and procedures for all staff members. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 5 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 7 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 399 1.3 School Safety Legal Standard The LEA has developed a comprehensive safety plan that includes adequate measures to protect people and property. (EC 32020, 32211, 32228-32228.5, 35294.10-35294.15) Findings 1. The district BP 0450-Comprehensive Safety Plan was last revised in April 2019. It requires each SSC to develop a Comprehensive School Safety Plan relevant to the needs and resources of that school. EC 32280-32289.5 outlines the requirements for schools, operating any kindergarten and any grades 1 to 12, inclusive, in writing and developing a school safety plan relevant to the needs and resources of that school. FCMAT verified that all sites had Comprehensive School Safety plans available, but not all sites had approved them through their respective SSCs in accordance with SB 187, SB 334 and AB 1747, and two school sites had not updated the plan for this review period. All had them readily accessible on site and links to copies were posted online, but the links were not working during FCMAT’s fieldwork. 2. AR 3516-Emergency and Disaster Preparedness Plan was last updated in April 2019 and outlines plan requirements for fire drills (AR 3516.1), bomb threats (AR 3516.2), earthquake emergency procedures (AR 3516.3) and emergency schedules (BP 3516.5) at school sites. All site principals reported they routinely scheduled and performed fire drills and earthquake drills in accordance with board policy, although they could not provide written evidence of the drills at every site. 3. Except for Worthington and Payne Elementary schools, principals reported that fire alarm systems operated correctly. Worthington Elementary does not have a separate fire alarm system, so the operative fire alarm consists of manually ringing the regular school bell for five seconds. The Payne Elementary system required two separate alarms to be pulled at two different locations on the campus for the alarm to be heard throughout the campus. Morningside High School indicated that its system was newly constructed and functioning. Oak Street Elementary indicated there were no fire alarms in its modular classrooms. 4. Staff reported the public address systems at five sites, Morningside High School, Oak Street Elementary, Kelso Elementary, Highland Elementary, and Payne Elementary are not fully functioning and could not be heard throughout the entire campus. Worthington Elementary indicated it does not have a working public address system. 5. 5. The district uses a third-party vendor to perform annual inspections of its fire extinguishers throughout the district. At each school site, FCMAT audited a sample of fire extinguisher tags that indicated almost all were inspected in August 2022. FCMAT found some instances in which fire extinguishers had not been inspected in the past year. Also, no evidence indicated they had been checked or inspected regularly for pressure other 400 Facilities Management than the annual inspection. The district continues to maintain an account with an outside vendor for central station monitoring, fire extinguisher recharging, emergency lighting and kitchen hood extinguishers districtwide to comply with fire marshal inspections and Williams Act requirements. 6. Six school sites have a primary single point for campus entry prior to school start; but all other school sites have more than one point of entry before school. All schools maintained a single point of entry during school hours. Recommendations for Recovery 1. The district should update and maintain its Comprehensive School Safety plans according to BP 0450. Individual school sites should have their safety plans adopted by their SSCs annually. 2. The district should continue to schedule and perform fire drills and earthquake evacuation drills in accordance with AR 3516.1 and BP 0450, respectively. The district should require school sites to provide their updated fire and earthquake drill schedules at the beginning of each fiscal year and should require monthly documented verification that the drills were completed. 3. The district should evaluate and address the two independent fire alarm systems at Payne Elementary and the need for a new, independent fire alarm system at Worthington Elementary. The district should expand its fire alarm capabilities to the modular classrooms at Oak Street Elementary. 4. The district should evaluate and repair the partially operable public address systems at Morningside High School, Oak Street Elementary, Kelso Elementary, Highland Elementary, and Payne Elementary. The district should implement a new operable public address system at Worthington Elementary so that announcements can be heard in all areas of the campus. 5. The district should continue to annually inspect the fire extinguishers throughout the district. The district should ensure fire extinguishers have been checked monthly and the tag is initialed on the back by the person who does the checking. Site staff should be trained to perform and record these monthly fire extinguisher visual inspections for proper pressure. Site staff should immediately notify the site principal and the deputy chief maintenance and operations officer of any fire extinguishers that are out of date, have missing pins, tags, or are in any way potentially not fully operable. 6. The district should consider always using a single point of entry before school, and maintain the use of visitor sign-in logs for each of its school sites. The use of visitor identification badges should be considered at all school sites. Facilities Management 401 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 402 Facilities Management 1.8 School Safety Legal Standard School premises are sanitary, neat, clean and free from conditions that would create a fire or life hazard. (CCR Title 5, Section 630) Findings 1. The school facilities visited by FCMAT were mostly clean and free of debris and conditions that would create a fire or life hazard. At some sites visited by FCMAT, visible areas such as building and hallway corners had debris and litter. 2. Restroom facilities inspected by FCMAT at all sites were mostly free of debris and conditions that would create fire or life hazard. Many restrooms throughout the district contained new toilet and sink fixtures; however, missing or broken partitions were noted at Bennett-Kew Elementary; damaged or missing sinks at Morningside High School; broken and inoperable toilets and soap dispensers at Woodworth-Monroe, City Honors, and Hudnall Elementary; and graffiti in the restrooms at Inglewood High School. Most restrooms visited by FCMAT were aging with worn flooring and stall partitions, and staff at several sites indicated they have concerns about the restrooms being cleaned regularly. Throughout the district, bathrooms no longer appear to be periodically and consistently inspected throughout the day. Student restroom facilities at some school sites were locked and not inspected. 3. All kitchen facilities visited by FCMAT were found to be clean, and the equipment appeared to be in good working condition. 4. An outside vendor has completed annual fire extinguisher inspections at all sites. No school sites visited by FCMAT showed any evidence of monthly fire extinguisher inspection checks by district employees as demonstrated by the lack of written initials on the back of the individual inspection tags. 5. Staff interviewed by FCMAT indicated that fire alarms had been tested at all sites. Staff also indicated that the fire alarm system at Kelso Elementary had been inoperable but was recently repaired and is now functioning properly. Information provided to FCMAT indicated that a new system had been installed at Inglewood Continuation High School, and that the system at Payne Elementary still requires the pulling of two separate pull stations to fully operate. Worthington Elementary does not have a separate fire alarm system, so the operative fire alarm consists of manually ringing the regular school bell for five seconds. Oak Street Elementary indicated there were no fire alarms in its modular classrooms. 6. No playground inspections were performed during the period under review. The school site playgrounds were last inspected professionally by Poms and Associates in 2017. District staff indicated that Poms and Associates are scheduled to perform playground inspections prior to the end of the school year. 7. The district did not complete any performance evaluations for site custodians since the last visit by FCMAT, although the district has indicated it intends to complete them prior to June 30, 2023. Site principals are responsible for performing custodial evaluations in Facilities Management 403 collaboration with the deputy chief maintenance and operations officer and custodial supervisor. The principals interviewed by FCMAT stated they have daily oversight of the custodians. 8. FCMAT found all sites had up-to-date safety data sheet (SDS) binders. The SDS binders were in the school offices at each school site except for Payne Elementary, which had its binder in the custodial closet. SDS training for custodial employees or other staff members had not occurred during this review period. 9. District staff indicated that site custodians perform regular daily inspections on their respective campuses to ensure that all appropriate doors are secured, and potential hazards are properly identified and addressed. 10. The district was undergoing a major repair of a leaking gas line at Morningside High School during FCMAT’s visit. The campus had been shut down to students for a few weeks allowing only virtual instruction, but the leak was reported fully repaired prior to the end of fieldwork, and students were expected to return to in-class instruction the following week. Recommendations for Recovery 1. The district should continue to work to improve the cleanliness of its campuses. Custodial staff should continue to be trained and held accountable to inspect all areas more diligently, both visible and nonaccessible, for removal of trash and debris. 2. The district should continue its efforts to always maintain the cleanliness of its school site restroom facilities. Custodial staff should be held accountable to maintain the cleanliness of restroom facilities throughout the day. Periodic restroom inspections should be reestablished throughout the day using the daily inspection form at school sites to ensure they contain all necessary products and working dispensers to include toilet paper, soap, sanitizer, and toilet seat covers. 3. The district should continue to maintain the cleanliness and operability of its school kitchens and their equipment. 4. The district should continue to perform its annual fire extinguisher inspections and reestablish monthly inspections of the fire extinguishers by district personnel. 5. The district should continue to have fire systems tested annually at all sites and repairs made as necessary to ensure full functionality. 6. The district should conduct annual playground safety inspections through the certified playground safety audits conducted by the district’s property and liability insurance provider and correct any deficiencies identified. 7. The district should complete its annual custodial evaluations, with the site administrator having primary responsibility for their completion, and the deputy chief maintenance and operations officer and custodial supervisor providing input as needed. 404 Facilities Management 8. The district should continue to ensure up-to-date SDS binders are maintained and accessible at each of its school sites, and that all necessary staff members know their location and are well versed in their use. 9. The district should continue regular inspections by its custodial personnel on their respective campuses to ensure that all appropriate doors are secured, and potential hazards are properly identified and addressed. The district should consider having site lead custodians visit other sites to help identify issues that may have gone unnoticed and to learn from one another. 10. The district should continue to move forward with facility improvement plans to address site safety and habitability issues that are beyond the scope of regular and routine maintenance. Plans should include the repair or updating of aging student restroom facilities in the district, particularly floors and stall partitions. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 3 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 405 1.9 School Safety Legal Standard The LEA complies with Injury and Illness Prevention Program (IIPP) requirements. (CCR Title 8, Section 3203) Findings 1. BP and AR 4257-Employee Safety and BP 4257.1-Work Related Injuries were last updated in August 2014 and require the superintendent or designee to establish and implement a written IIPP in accordance with Labor Code Section 6401.7. AR 4257.1-Work Related Injuries was last updated in February 2019, and AR 4257.2-Ergonomics was last updated in April 2019. 2. The district has an IIPP binder in the district office dated February 1, 2017. The district has its IIPP posted on the district website, but it contains no date of origin, no record of trainings or inspections, and it is unknown if the information is up to date. The IIPP binder contains a Health and Safety Officer Designation Form that designates an employee who is no longer with the district as the health and safety officer. 3. The district offers ongoing and annual workplace injury and illness prevention training to employees through a web-based application known as Keenan Safe Schools. The program provides training specifically related to the requirements outlined in the IIPP, such as workplace injury prevention, workplace safety, and other annual mandated training. The program also maintains a record of all annual training completed by district employees. The district website contains links to the online training for employees through the HR and Risk Management tabs. 4. The district had previously established a District Safety Committee, but it has not held any meetings since February 2021. 5. The district indicated that there has been no districtwide training that included workplace safety training for employees during this review period. Recommendations for Recovery 1. The district should review and update its BPs and ARs 4257, 4257.1 and 4257.2 as necessary to keep up to date with laws and regulations. 2. The district should update the IIPP to ensure that it includes the designation of an active employee as the health and safety officer for the district, as well as appropriate identification of contacts, documentation of trainings and inspections, and the most current district applicable information. The district should post its revised and updated IIPP on the district webpage and notify all employees of its availability. 3. The district should continue to provide annual employee training as related to the requirements of the IIPP. The district should ensure IIPP training is provided to all new 406 Facilities Management employees, employees who are new to their job assignments, and existing employees to refresh their awareness of safety procedures. 4. The district should consider the reestablishment of a District Safety Committee and have the IIPP regularly reviewed as part of the committee’s duties. 5. The district should provide, at a minimum, annual districtwide staff development that includes safety training. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 3 July 2016 Rating: 2 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 7 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 407 1.15 School Safety Legal Standard The LEA maintains updated Material Safety Data Sheets (MSDS) for all required products. (LC 6360-6363; CCR Title 8, Section 5194) The global harmonization system was developed in 1992 and slowly implemented throughout the world during the past 20 years. Implementation in the United States occurred in 2012 and has replaced the MSDS system with the SDS system. The SDS system utilizes a readily available binder for providing safety information on all custodial cleaning products. Findings 1. The district last updated BP 3514.1-Hazardous Substances on April 17, 2019. The board policy reflects current requirements and is posted on the district website. 2. FCMAT found all sites had up-to-date SDS binders. The SDS binders were in the school offices at each school site except for Payne Elementary, where it was located in the custodial closet. 3. Staff indicated that no training has been provided regarding the use of the SDS binder during this review period. 4. In 2019 the district developed a comprehensive Hazard Communications Program document to provide information and guidelines for all employees who use hazardous materials. Staff indicated it is no longer in use by the district, and that no training in the use or safety requirements of hazardous materials has been provided during this review period. Recommendations for Recovery 1. The district should continue to maintain its BP 3514.1-Hazardous Substances and update as needed. 2. The district should continue to keep its SDS binders up-to-date, ensure the binders are stored in a readily accessible location, and all site personnel are aware of their location. 3. The district should provide annual training in the use of the SDS binder, the information they contain and their location. Any training should be documented with agendas and sign-in sheets. 4. The district should consider reestablishing its Hazard Communications Program to ensure there is a safety program that discusses the specific safety protocols and responsibilities associated with the use of hazardous materials and SDS, including the addition of SDS training dates. If reestablished, the district should review and revise the program, as necessary. The district should also consider adding SDS use and accessibility information to the IUSD Custodial Handbook. 408 Facilities Management Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 3 July 2018 Rating: 5 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 409 1.16 School Safety Professional Standard The LEA has a documented process for issuing and retrieving master and sub-master keys. All administrators follow a standard organization-wide process for issuing keys to and retrieving keys from employees. Findings 1. The district last updated AR 3515-Campus Security, in August 2014, which specifies the following: All keys used in a school shall be the responsibility of the principal or designee. Keys shall be issued only to those employees who regularly need a key in order to carry out normal activities of their position. The principal or designee shall create a key control system with a record of each key assigned and room(s) or building(s) which the key opens. Keys shall be used only by authorized employees and shall never be loaned to students. The master key shall not be loaned. The person issued a key shall be responsible for its safekeeping. The duplication of school keys is prohibited. If a key is lost, the person responsible shall immediately report the loss to the principal or designee and shall pay for a replacement key. 2. The principal at each school site is responsible for the issuing of keys to site staff members. Each site has a system for the issuance and retrieval of keys at its site. The deputy chief maintenance and operations officer oversees the issuing of new keys throughout the district and shares that responsibility with the maintenance supervisor. Information from the sites is collected and maintained regarding key inventory and issuances. 3. All site administrators reported that the issuance process, forms, and replacement of lost keys process has been implemented and is consistent with board policy and indicated to FCMAT that their sites maintained a system to check out and return all keys assigned to teachers, substitutes and other staff. All keys assigned to teaching and classified staff are relinquished to the principal on the last day of school. No keys are authorized to be maintained by staff members on summer break. 4. The district uses independent contractors to help repair locks and cut keys. All keys are issued to sites from the central operations office. Even after a new lock is installed, keys are issued by the Maintenance Department and not by the independent contractors who performed the installation. At one site visited by FCMAT, a custodial closet was inaccessible because a substitute custodian had broken off a key in the door, and it had yet to be repaired. 5. Since the district does not have a standardized lock system for the district or for individual sites, FCMAT continues to observe many administrative and custodial staff carrying many keys to access all locked areas at their sites. FCMAT observed instances in which 410 Facilities Management staff members could not open doors or locks because the appropriate key was not readily available. Also, because lock and key systems lack uniformity, the district cannot issue to district- level officials a specific master or submaster key that is operable at all sites. 6. The district implemented a new Schlage key and lock system at Payne Elementary, which has one master key, and has significantly reduced the number of keys used by site staff. 7. In a previous interview with FCMAT, the former CBO reported that the district was developing a request for proposals (RFP) for the implementation of a new districtwide key and lock system. However, staff indicated this RFP was not developed, and has established no plans to do so in the immediate future. Recommendations for Recovery 1. The district should review and revise its BP and AR 3515 to ensure they are applicable and accurate. 2. The sites should continue to forward to the appropriate district authority a copy of the key inventory to include specific information on issued keys such as the purpose, the name of the person who was issued the key, and the individual who issued it. 3. The district school sites should continue to maintain their site-based control system for the annual issuance and retrieval of keys. 4. The district should continue to issue new keys centrally from its Maintenance Department and maintain accurate records of all new keys issued to school sites. 5. The district should ensure that all site administrators always have the proper keys to access every room, building, or gate on their campus. School site administrative and custodial staff should perform an annual walk-through inspection of their campuses to check all gates and doors to ensure they have and identify the proper keys to access all areas of the campus. 6. The district should continue to prioritize and implement the use of a districtwide standard lock and key system for all facilities and develop a plan to systematically replace the older lock systems at the sites with the new system. This will help eliminate the large number of keys required by site administrative and custodial staff. Facilities Management 411 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 412 Facilities Management 1.18 School Safety Professional Standard Outside lighting is properly placed and is monitored periodically to ensure that it functions and is adequate to ensure safety during evening activities for students, staff and the public. Findings 1. The district does not have board policy or facilities standards that specifically address the adequacy of outside lighting. AR 3515-Campus Security was last updated in August 2014 and outlines strategies that include a risk management analysis of each campus’ security system, lighting system, and fencing. In November 2016, the district developed a document titled District Standards, which includes Section 265619 outlining construction requirements for exterior lighting. 2. According to the work order summary provided by the district for this review period, outdoor/exterior lighting was repaired at Worthington Elementary in February 2022, and at Parent Elementary in January 2023. New exterior lighting has been installed at Oak Street Elementary as part of its recent renovation. 3. The Maintenance, Operations and Transportation Department continues to have an internal document known as the School Inspection Report to assess school site facility conditions; however, no School Inspection Reports were completed during this review period. The report does not assess exterior lighting conditions. Staff indicated they walk three sites per week inspecting facilities with principals. 4. All sites had exterior lighting that appeared to be in working order, and no complaints or concerns were expressed in any FCMAT interviews regarding deficiencies in exterior lighting. Recommendations for Recovery 1. The district should consider developing written standards for exterior campus lighting as part of AR 3515. The district should continue to include construction requirements for exterior lighting in its District Standards reviewing and updating them regularly. 2. The district should continue to repair and improve exterior lighting regularly as requested through its work order system. 3. The district should use the School Inspection Report monthly at each site and update the form to include an inspection item to evaluate exterior lighting. 4. The district should continue to evaluate the outside lighting during evening hours at all sites and provide temporary lighting as needed to ensure adequate exterior lighting levels and safety are maintained. Facilities Management 413 Standard Partially Implemented July 2013 Rating: 5 July 2014 Rating: 5 July 2015 Rating: 6 July 2016 Rating: 5 July 2017 Rating: 5 July 2018 Rating: 5 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 7 July 2023 Rating: 7 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 414 Facilities Management 1.20 School Safety Professional Standard The LEA maintains a comprehensive employee safety program. Employees are made aware of the LEA’s safety program, and the LEA provides in-service training to employees on the program’s requirements. Findings 1. BP and AR 4157-Employee Safety were last updated in August 2014 and require the superintendent or designee to promote employee safety and correct any unsafe work practices through education and enforcement. Comprehensive School Safety plans were available and accessible at all school sites, and on the district website. 2. Workplace safety training for employees is provided entirely through the online Keenan Safe Schools training program available from the district’s property and liability JPA. 3. The district no longer has an active District Safety Committee. The committee consisting of members of the district leadership team, labor union leaders, and other district employees last met in February 2021. Recommendations for Recovery 1. The district should review and update BP and AR 4157-Employee Safety as needed and should review and update the Comprehensive School Safety plans annually. The district should continue to make those plans available at school sites and on the district webpage. 2. The district should provide districtwide workplace safety training to all employees annually. The district should also continue to provide ongoing workplace safety training for all employees through the online Keenan Safe Schools training program. The district should ensure that all employees, including substitutes, receive safety training according to the requirements for each position, job title, and school site. Training records should be maintained and kept in a single location so they can be reviewed regularly to ensure actions are completed according to the District Safety Plan, board policy requirements, and to coordinate training activities between departments. 3. The district should consider reestablishing its District Safety Committee to review and communicate district safety issues and concerns and provide direction to staff regarding urgent or important safety concerns. Facilities Management 415 Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 5 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 416 Facilities Management 2.2 Facility Planning Legal Standard The LEA seeks and obtains waivers from the State Allocation Board (SAB) for continued use of any nonconforming facilities. (EC 17284-17284.5) This standard is no longer applicable under current law and will be eliminated from the evalua- tion process and scoring rubric. Standard Not Applicable July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: N/A July 2016 Rating: N/A July 2017 Rating: N/A July 2018 Rating: N/A July 2019 Rating: N/A July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: N/A July 2022 Rating: N/A July 2023 Rating: N/A 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 417 2.3 Facility Planning Legal Standard The LEA has established and uses a selection process to choose licensed architectural/engineering services. (GC 4525-4526) Findings 1. BP and AR 7140 on the selection of architectural and engineering services were adopted in August 2014 and require the superintendent or designee to devise a competitive process for choosing architects and structural engineers that is based on demonstrated competence and on the professional qualifications necessary for the satisfactory performance of the services required. The district followed a competitive process on the March 2021 RFQ for architectural and engineering services. 2. The district issued a RFQ dated March 29, 2021, for architectural services related to Measure GG, Measure I, modernization, and new future construction projects. The district used the RFQ to create a new pool of architectural consultants and is using this list to enter new contracts. This RFQ may be annually approved by the school board with a limit of five years, so it may be used until April 13, 2026. In addition, the RFQ includes project services such as working with the district’s demographic consultant to create a well-developed plan and prepare and update a long-range facilities master plan and educational specifications. 3. The district’s March 2021 RFQ did not adequately state new potential projects and potential state requirements to acquire future state funding, even though it defined that the architects will be required to make their expert assessments of the district’s facilities and be a part of developing the projects that will meet the district’s needs and priorities. The RFQ does not appear to include all the projects referred to the Citizens’ Bond Oversight Committee (CBOC) in early 2023. The Bid Opportunities website link also does not include this project information. Staff indicated the district is moving forward with the design and modernization of Inglewood High School as well as projects identified by the CBOC. The RFQ issued does not appear to include these projects. If the district is planning on acquiring state funding for these projects, it will need to provide evidence- based information that shows the district issued a RFQ meeting state requirements including contract requirements such as Disabled Veteran’s Business Enterprise and construction prequalification information as it applies to the defined projects list. 4. The district’s 2017 RFQ included detailed educational specifications for elementary, middle, and high school levels with a direction to the selected architectural pool to include the design services necessary for the final defined work. The 2017 RFQ included complete services needed and a defined fee for services schedule. However, it was limited to the number of approved projects. 5. The district developed building standard specifications in 2017, and it appears that no reevaluation has been considered or completed. Reevaluation should occur at least every two years as building standard specifications change regularly, or even more frequently 418 Facilities Management when major changes occur such as specifications for technology, learning environment, and safety. The best practice is to establish a committee of knowledgeable district staff (such as the deputy chief maintenance and operations officer, maintenance staff experienced in the specific trade involved, other appropriate administrative and finance staff, and teachers) to review and recommend changes to the standard specifications ensuring they are up to date and compliant with construction industry standards and education standards. The committee would review and edit the standard specifications in consideration of the district needs and product capabilities. The committee would then communicate recommendations to the county administrator/board for approval. FCMAT found no indications that the district made any progress or efforts to evaluate and update the specifications as necessary. Recommendations for Recovery 1. The district should continue to follow the process outlined in BP and AR 7140 for selecting architectural services on future district projects. This policy should be revisited regularly and revised as necessary to ensure it meets the district’s needs and the industry best practices. The board policy and administrative regulation should include the last date reviewed and/or updated. 2. The district should create a new RFQ to ensure selection of the most qualified architectural firm(s), including all supporting consultants, to create a plan for the district’s projects and help the district meet the requirements as identified and established by the district. The new RFQ should include all projects that the district plans to construct for the period of five years, including what is required to be eligible for state funding and the projects approved by the district. 3. The new RFQ should not be the sole criteria for determining architectural services. Special projects may require architects with different skills, special knowledge, and experience. When this occurs, include an independent, well-defined and complete educational specification on each project and a well-defined description to request appropriate architectural services. When significantly complex projects are determined, such as those at Inglewood High School, the present RFQ list of qualified architectural consultants may not meet project needs, and the district should consider developing a new separate project-specific RFQ identifying the actual needs required. The projects may also require special consultants. If this is the case, the district should determine this and require that the architectural agreements include special consultants with a fixed all-inclusive consultant’s fee. With the current significant increase in construction cost, fee evaluation should also be considered when selecting the architectural firm. 4. Because several specific types of architects and consultants will probably be needed to do the different types of projects, specific project specifications will be needed. For example, the district should consider issuing a separate RFQ for an architect who prepares detailed educational specifications. This architect may be considered ineligible to provide services for the related projects because of a possible conflict of interest due to having greater knowledge of the projects. The district should seek advice from its legal counsel about a possible conflict of interest if it wants to use the same architect for design specifications and to provide services for those projects. Facilities Management 419 5. The district should evaluate and update the building standard specifications. These standard specifications should be reviewed, edited and updated at least every two years, or more frequently if major developments occur. In consideration of cleaning and wear, maintenance and custodial staff should have input on materials specified. Once standard specifications and building standards are completely developed and evaluated, updated and adopted, the district should establish a consistent committee of experienced evaluators to continue to review and make recommendations to the standard specifications. The county administrator/board should consider and approve some standardized items that should be consistent throughout the district while allowing others to be site or department specific as necessary. Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 4 July 2016 Rating: 6 July 2017 Rating: 6 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 7 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 420 Facilities Management 2.6 Facility Planning Professional Standard The LEA has a long-range school facilities master plan that has been updated in the last two years and includes an annual capital planning budget. Findings 1. BP 7110 states, The Board of Education recognizes the importance of long-range planning for school facilities in order to address changes in student enrollment and in the dis- trict’s educational program needs. The Superintendent or designee shall develop, for Board approval, a master plan for district facilities which describes the district’s anticipated short- and long-term facilities needs and priorities. The district's facilities master plan shall be based on an assessment of the condition and adequacy of existing facilities, a projection of future enrollments, and align- ment of facilities with the district’s vision for the instructional program. 2. The district last revised BP 7110 for developing a facilities master plan (FMP) on February 20, 2019. 3. Staff reported that the district’s FMP has been completed and approved, although no final plan has been shared with FCMAT. However, the district’s Facilities, Maintenance, Operations and Transportation webpage has a link titled Facilities Master Plan 2023. Following the link, a document titled Inglewood Unified School District Facilities Master Plan 2022 is found. 4. This Facilities Master Plan appropriately includes a district introduction, current site conditions, and analysis and recommendations. The Introduction section includes district historical background, mission and goals, district schools list and map, demographic trends, capacity analysis and enrollment trends. The current site conditions section, titled Ready from Day One, includes academic goals and performance, facility conditions, site and building conditions, functionality and health and wellness. The Analysis and Recommendations section includes information by school site such as an overview of each site, existing conditions, proposed opportunities, and associated costs broken down by immediate and 2-10 years. The FMP includes data on the utilization (site capacity to enrollment) of each site, which identifies significant underutilization at most sites. The report also identifies facilities underutilization in the district overall with a capacity of 14,738 without portables and the 2021-22 enrollment at 5,661 students. In addition, the FMP enrollment projection shows an annual decline varying from 2.7% to 3.7% through 2028-29. As enrollment continues to decline, the district’s facilities underuse continues to grow. Much of these excess facilities are old and in poor condition and require substantial effort to maintain. Over the past two years significant improvements have been made in addressing facility issues; however, the district is still faced with the need for removal of many unused classrooms and buildings. Until the district is “right-sized,” it will need Facilities Management 421 to continue maintaining all its facilities on a maintenance budget sized for the district’s student population and marginally adequate for a district with significantly fewer facilities. 5. The district began the process of “right sizing” its facilities in 2019 with the removal or demolition of some excess portable classrooms and the combining of Woodworth Elementary and Monroe Middle schools. In 2022, the Warren Lane Elementary site was closed to district students. Discussions concerning future planning have continued with the School Closure and Consolidation Committee during this review period. It is apparent from the meeting minutes provided, the district is acquiring vital information to make well educated decisions; however, no final direction had been determined at the time of FCMAT’s fieldwork. 6. The district continues to expend funds on repairs or modernization of portables at various school sites. The district should generally avoid investing in these projects unless a thorough analysis is completed, and it is determined this is the best fiscal and operational choice. In general, the district should invest all improvement funds in modernizing permanent facilities rather than improving facilities that are considered temporary such as portables. In addition, the removal of dilapidated portables would help the district in its right-sizing efforts. 7. During the 2019 FCMAT interviews, the district commented that Morningside High School’s athletic facilities should be updated to world-class status. During this year’s site visit, FCMAT observed improvements on the campus included modernization of classrooms, auditorium, a new gaming classroom, and many other areas. New improvements at Coleman Stadium had just begun during FCMAT’s visit. 8. The new requirement to place universal transitional kindergarten (UTK) on school campuses was not discussed, but funding for UTK facilities could be a way to replace old dilapidated portable classrooms with new permanent modular buildings on a concrete foundation. This process could put UTK students in an over 50 year life span classroom facility. 9. FCMAT’s review of information provided to the district’s CBOC, information from staff interviews, and a review of actual construction projects during site visits show that the district is continuing with facility improvements. Staff indicated that the CBOC had included some school closure considerations in their discussions. 10. The district retained Davis Demographics to perform a demographic study. The demographic study was completed January 25, 2022. 11. The status of Los Angeles World Airports (LAWA) funding for the district is unknown. The latest information provided to FCMAT shows that the district was approved for $40 million in LAWA funds that needed to be spent by September 2021. No further information has been provided regarding the expenditure of those funds or whether future funds may become available to the district. 422 Facilities Management Recommendations for Recovery 1. The district should regularly review and update BP 7110 as needed to ensure it addresses changes in student enrollment and in the district’s educational program needs while remaining compliant to current law and best practices. The district should continue to note the date of last review and revision. 2. The district should review, revise, update and adopt its FMP and continue to do so regularly or at minimum every other year. When developing the FMP, the district should incorporate a funding component based on the estimated costs of needs and available resources including information and recommendations from the School Closure and Consolidation Committee, CBOC and Asset Management Advisory Committee. 3. The district should use updated enrollment projections to update its facilities needs assessment and the FMP at least every other year. This plan will help clearly define the district’s facilities current status and needs by each attendance boundary and site. This information will serve as a basis and provide the district a continual information source for all future facilities planning of the district. 4. The FMP should include a timeline of recommended execution of facility projects on an immediate, five-year and future consideration basis. 5. The district should continue to recognize and address its excess facilities focusing first on reducing temporary structures and structures in major disrepair while also considering educational and operational needs, costs and funds available. 6. The district should focus its expenditures on improving and maintaining its permanent structures. If the need exists, leasing of portables should be limited to no greater than a 59-month term to avoid affecting state funding eligibility. In addition, the new requirement to place UTK on school campuses could be an opportunity to replace existing portable classrooms with new permanent modular classrooms on a concrete foundation with a life expectancy of over 50 years. 7. The district should continue communications with the CBOC, the School Closure and Consolidation Committee and the Asset Management Advisory Committee, including having each committee regularly report out to the county administrator/board. 8. The district should continue to use information obtained from the demographic study dated January 25, 2022, to align facilities capacity with its current and projected student enrollment. In addition, the district should consider keeping the demographics study current every other year. This information will be valuable to the district’s advisory committees and assist in the right-sizing determinations as time proceeds. 9. The district should ensure an administrator is identified and responsible for tracking LAWA opportunities to maximize this funding and pursue further eligibility of school sites for future LAWA funding sources. This includes following up with LAWA on any projects previously submitted for reconsideration of funding and appealing previously denied LAWA funding projects. Facilities Management 423 Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 4 July 2015 Rating: 6 July 2016 Rating: 6 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 3 July 2023 Rating: 5 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 424 Facilities Management 2.8 Facility Planning Professional Standard The LEA has a facility planning committee. Findings 1. BP 7110-Facilities Master Plan was last revised February 20, 2019, and states in pertinent part the following: To solicit broad input into the planning process, the Superintendent or designee may establish a facilities advisory committee consisting of staff, parents/guardians, and business, local government, and other community representatives. He/she also shall ensure that the public is informed of the need for construction and modernization of facilities and of the district’s plans for facilities. 2. The district formed several district advisory committees to perform oversight evaluation and provide community input and recommendations to the district. Those active over the past few years include CBOC, District Real Property Advisory Committee (2017-18), Asset Management Advisory Committee (2022), and School Closure and Consolidation Committee. The committees are to evaluate and to provide feedback on the following: • Determine enrollment projections and their impact on surplus space. • Inventory the capacity and the conditions of existing facilities. • Determine per-student operating cost at each facility. • Evaluate specific schools considered for closure. • Identify specific new environmental/safety concerns for each site. • Determine projected cost-savings for each school considered for closure. • Identify housing/transportation options for displaced students. • Consider cost benefits of varying property disposition/use options. • Recommend transition strategies. • Provide specific information and make recommendations about each school site to the county administrator/board. 3. The district previously had a District Real Property Advisory Committee, but this committee has not met since January 17, 2018, and its last and final report was presented to the then-state administrator/advisory board on February 7, 2018. 4. The district has continued with the present CBOC for Measure GG and Measure I under previously established bylaws for the CBOC to define the role of committee members, which is to ensure conformance with the ballot language of Measures GG and I. The CBOC holds regular meetings always maintaining a quorum. Meeting agendas show the Facilities Management 425 committee has conducted several meetings during this review period: March 2, 2022, May 18, 2022, June 15, 2022, September 21, 2022 and January 26, 2023. In addition, the CBOC has scheduled meetings through August of 2023. 5. The district’s Asset Management Advisory Committee began with its first meeting in October 2022 and held a subsequent meeting in November. Scheduled meetings for December 2022 and January 2023 were cancelled. Members include various community, business, and district representatives. A review of meeting minutes identified that the committee is still in its developmental stage with much of the discussion being about roles, responsibilities, bylaws and current status of facilities. 6. The district’s School Closure and Consolidation Committee first met for the 2022-23 year on October 27, 2022. A meeting was scheduled for October 17, 2022, but was cancelled due to lack of quorum. The committee held six meetings in 2021-22 between September 2021 and January 2022. Committee members include parent, district staff, business, landowner, and community representatives. A review of meeting minutes revealed that information presented to the committee include the following topics: facility and fiscal implications, educational services, district comparison, fiscal stabilization, alignment of resources, right-sizing, school criteria ranking, scatter plot and local school maps, and school closure options. 7. The oversight committees are essential to the development of the FMP, and to district and public trust. 8. The CBO serves as the district’s resource person for these committees. Both current and previous CBOs dedicated a significant amount of time to increasing the committees’ understanding of school facilities planning and construction. The district’s facilities and operations staff and the consultants for facilities and construction have also provided support and information to the committees. Recommendations for Recovery 1. The district should review and revise BP 7110 regularly to ensure it accurately addresses the district’s needs and direction. In addition, the district should indicate the date of the latest review and/or revision. 2. The district should continue to support the district’s advisory committees to ensure they meet regularly, follow their intended purpose, and have access to information that can be used to devise recommendations to the county administrator/board. 3. In addition to the CBO, the position responsible for facilities and operations and the district’s architectural and construction management consultants should continue to provide detailed funding, costs and project progress reports regularly to the district advisory committees. 4. Project progress reports presented should include information for the reporting period and include information spanning the entire term of the project to provide committee members, old and new, a complete picture of costs and project budget. 426 Facilities Management 5. Information from advisory committees’ meetings including concerns and recommendations should be memorialized in meeting minutes and communicated to district staff and the community. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 0 July 2022 Rating: 0 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 427 3.1 Facilities Improvement and Modernization Legal Standard The LEA maintains a plan for maintaining and modernizing its facilities. (EC 17366) Findings 1. Through BP 7000, the district’s board recognizes that one of its major responsibilities is to provide healthful, safe, and adequate facilities. The board endeavors to make the provision of adequate school facilities a priority in the district. Included in the 7000 series of board policies is BP 7110-Facilities Master Plan. This policy requires the FMP to be based on an assessment of the condition and adequacy of existing facilities, projection of future enrollments and alignment of facilities with the district’s vision for the instructional program. The district last revised BP 7110 on February 20, 2019. 2. District staff indicated the FMP had been completed and approved although no finalized plan has been shared with FCMAT. However, under the district’s Facilities, Maintenance, Operations and Transportation webpage, there is a link titled Facilities Master Plan 2023. Following the link, a document titled Inglewood Unified School District Facilities Master Plan 2022 is found. This FMP appropriately includes a district introduction, current site conditions, and analysis and recommendations. The Introduction section includes district historical background, mission and goals, district schools list and map, demographic trends, capacity analysis and enrollment trends. The site conditions section, titled Ready from Day One, includes academic goals and performance, facility conditions, site and building conditions, functionality and health and wellness. The Analysis and Recommendations section includes information by school site such as an overview of each site, existing conditions, proposed opportunities, and associated costs. The FMP includes data on the utilization (site capacity to enrollment) of each site, which identifies significant underutilization at most sites. The report also identifies facilities underutilization in the district overall with a capacity without portables of 14,738 and the 2021-22 enrollment at 5,661 students. In addition, the FMP enrollment projection shows an annual decline varying from 2.7% to 3.7% through 2028-29. As enrollment continues to decline, the district’s facilities underuse continues to grow. Much of these excess facilities are old and in poor condition and require substantial effort to maintain. Over the past two years significant improvements have been made in addressing facility issues; however, the district is still faced with the need for removal of many unused classrooms and buildings. Until the district is “right-sized,” it will need to continue maintaining all its facilities on a maintenance budget sized for the district’s student population and marginally adequate for a district with significantly fewer facilities. 3. Major infrastructure needs exist throughout the district, and some infrastructure components are beginning to fail. Examples include: • A main natural gas line failed at Morningside High School necessitating immediate repair and temporary closure of in-person instruction. 428 Facilities Management • Roof repairs remain a major issue that is leading to a significant structural problem on exit pathways at Inglewood High School. Failure to maintain and make timely repairs to facilities are leading to a much larger safety problem and repair project. 4. Documentation provided by the district to support maintenance projects included contracts for: • Paving at Oak Street Elementary. • Elevator maintenance at various sites. • Environmental compliance at various sites. • Fire alarm testing districtwide. • Waste recycling districtwide. • Defibrillator maintenance districtwide. • Hazardous materials testing districtwide • Gopher and pest control districtwide. • Field repair and maintenance at various sites. 5. Although requested, no evidence was provided to support the proactive planning of modernization projects, routine restricted maintenance projects, or deferred maintenance projects. 6. For the prior review, the following work was provided on an IUSD Maintenance, Operations and Transportation Plan Projects lists 2021-2022 Completed and Current Projects Lists and the Facilities and Maintenance Project Updates: • Woodworth-Monroe-Consolidation and site improvements have been completed to include new buildings, new playgrounds, joint property fence line, restroom privacy screens and meal services kiosk. • Morningside High School-Classroom renovations, exterior improvements, sound attenuation improvements, technology upgrades, plumbing system replacement, site improvements, landscaping/hardscape rehabilitation, security camera system upgrades, portable building renovations, pool window security mesh, shade structure, film animation room design, future marquee refurbishment. • Oak Street Elementary-New courtyard, building renovations and portable building repairs, sound attenuation improvements, classroom upgrades, technology upgrades and campus fencing. • Bennett-Kew Elementary-New portables, main entrance modifications, field upgrades, gas line infusion project, basketball court replacement and restroom renovation. Facilities Management 429 7. For this review period, the following maintenance and improvement projects were identified during FCMAT site walks: • Morningside High School–Auditorium renovation, shade structure, film animation room, and a gaming classroom. • Oak Street Elementary-Removal of temporary classrooms, shade structure, new marquee, and blacktop repairs. • Bennett-Kew Elementary–New portables for upper grades and restroom renovation in the main building. In addition, a new outdoor eating structure for the upper grades was under construction. • Crozier Middle School–Animation lab improvements • Coleman Stadium-Bleacher, track and field repairs were underway • Centinela Elementary–Building painting, metal rolling gate installed, and public address system repairs. • La Tijera Elementary–New marquee installed • Inglewood High School–Covered walkway removal and new animation room completed. 8. As of 2021, the district had hired an experienced deputy chief maintenance and operations officer who had invested time to evaluate the department. Under his leadership, the district had begun prioritizing and correcting some of the most important improvements. In 2022, the district hired a deputy chief facilities planning and construction officer. 9. Staff indicated the plan to relocate the district office to the adult school site has been stalled for two to three years pending funding and the continuation school relocation to the Inglewood High School site was moving forward. 10. The district’s routine restricted maintenance budget for 2022-23 is $6,015,006. The district’s deferred maintenance fund was budgeted at $360,082.21 for 2022-23. 11. The $90 million Measure GG general obligation bond has continued to be used as intended to provide funding for new construction, repairs, and modernization of school facilities. 12. The district is using Measure I, $240 million passed in November 2020, general obligation bond funds. The language for this measure states it is for Inglewood Unified School District student safety/health/achievement, classroom repair measure to repair/ upgrade classrooms, including instructional technology, vocational/career education, roofs, plumbing, security/fire safety; remove asbestos, lead paint, mold; provide safe drinking water; and acquire, construct, repair sites, facilities, equipment. 13. State bond funding is exhausted, and a new state bond measure may be presented to voters for consideration on the 2024 ballot. The state has been successful passing over $61 billion dollars since 1982. As of spring 2023, it appears the state will have support for the passage of a new state bond measure related to school facilities. The new bond 430 Facilities Management is expected to include new career technical education (CTE) funding and new UTK facilities funding for all school districts throughout the state. 14. This year, the district did not provide a current modernization eligibility calculation or support documents for the Inglewood High School project it stated it is planning. The planning for CTE facilities and supporting documentation for either Inglewood or Morningside High schools were also not included to support staff reports that planning for CTE facilities would be submitted to the Office of Public School Construction (OPSC) for future approval and potential state funding. Recommendations for Recovery 1. The district should continue regular review and updates of board policy series 7000 as needed. 2. The district should continue to review, evaluate and update its FMP and ensure it includes recommendations from the district’s Budget Advisory Committee (if active), CBOC, Asset Management Advisory Committee, and School Closure and Consolidation Committee. The FMP should include a current facilities assessment regarding the district’s facility needs, facility conditions and all funding resources. The new plan should be developed in consideration of acquiring and maximizing state, LAWA, and other complementary funding. The plan should include alternative viable proposals for modernization, demolition, and school consolidation/closure. 3. When updating the FMP, the district’s project changes and updates should be concisely identified, explained, documented, and summarized to allow the readers to understand the changes without reviewing the entire FMP. The plan should also include a recommended timeline of implementation. 4. The district should develop a plan to address the major infrastructure needs focusing on those that are at point of failure, pose safety threats, or will lead to a larger repair project if left unattended. 5. The district should maintain, and produce upon request, documentation to support modernization and maintenance projects planned throughout the district. 6. The district should maintain a listing of completed and active projects by year. 7. The district should maintain the positions to support the effective planning and managing of the district’s facilities such as the position of deputy chief maintenance and operations officer and deputy chief facilities planning and construction officer. 8. The district should coordinate and fully use its available funding to include routine restricted maintenance, deferred maintenance, general obligation bond, LAWA and other funds to support its facility’s needs. The district should note the state’s consideration to try to pass a state bond in 2024 and should consider getting all possible projects in position to acquire as much state funding as possible. Facilities Management 431 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 3 July 2015 Rating: 5 July 2016 Rating: 6 July 2017 Rating: 5 July 2018 Rating: 5 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic. July 2021 Rating: 5 July 2022 Rating: 6 July 2023 rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 432 Facilities Management 3.3 Facilities Improvement and Modernization Legal Standard All relocatable buildings in use meet statutory requirements. (EC 17292) Findings 1. No updated information was provided to FCMAT in response to this standard. 2. It appears the district continues to maintain an inventory of owned/leased portables with no new relocatable buildings were added since the prior review. 3. For the prior review, the district provided architectural records to FCMAT for most of its relocatable buildings. This information is several years in arrears and should be updated since it will be required to support future application for state funding. 4. The district has maps of each school site that displays the building layouts but excluded recent building/portable building changes and did not provide the year built and the Division of the State Architect (DSA) identification number for each portable. This information is several years in arrears and should be updated. This information will be required to support future application for state funding. 5. Architectural services were helping the district acquire DSA approval on all relocatable buildings and provide completed status site plans in previous years. However, the information is outdated, and the district should update its records as projects are completed. 6. The district had a historical practice of purchasing, or leasing through a long-term lease, relocatable buildings for use as permanent facilities. As a result, it continues to have a significant number of portable classroom units that are owned or leased for greater than five years. In either case, the portables count against the district’s eligibility for state facility funding. The district is working to remove nonessential relocatable classrooms. However, as found at the Oak Street Elementary and Bennett-Kew Elementary schools the district continues to install, remodel, improve and expend funds on portables considered essential for school operations by the district. 7. The district has declining enrollment and the ability to house most of its students in permanent facilities that are less than 25 years old. Therefore, even with the active removal of nonessential portable buildings, the district’s eligibility for state modernization funding is hampered since facilities are eligible for modernization funding at 25 years of age and older. Recommendations for Recovery 1. The district should maintain, and produce upon request, information regarding its relocatable building inventory and building lease/purchase information. Facilities Management 433 2. The district should continue to maintain an accurate inventory record of its relocatable buildings. 3. The district should continue to ensure its architectural records stay up to date on a project-by-project basis to ensure that all buildings meet statutory requirements. As the district determines a building does not meet the statutory requirements or district standards, the district should remove them. 4. The district should continue using architectural services to gain final DSA approval, close out and certify the status of all its relocatable buildings. The site plans provided by the architect should be complete with all buildings and each relocatable building identified separately with DSA identification numbers and year built. Once developed, the district should be able to reference them and use the information to determine future projects needed. These documents should be in a format that can be given to future architects and other contractors working for the district. They should also be in a format that can easily be displayed and shown to an audience such as at district board meetings. This process should be included in any architectural services contract and projects should not be closed out until this condition is met. 5. The district should continue evaluating the need for and use of all its relocatable/portable facilities and remove all unnecessary relocatable facilities. The district should consider removal of these facilities as an option to assist with the rightsizing of the district. 6. The district should evaluate and scrutinize the relocation of any classrooms to ensure more favorable options are not available and make certain the cost of relocating is worthwhile. The district should never expend funds on relocating dilapidated classrooms. 7. he district should limit its use of relocatable buildings to essential need and for less than 60 months. This process should be tracked and not allowed to extend beyond a five-year term as doing so will affect eligibility for state facility funding. 8. The district should continue determining long-term facility needs. When additional facilities are needed, the district should consider buildings on a concrete foundation. Manufactured classrooms on a concrete foundation can be built/installed faster and at a lower cost than permanent stucco/stud-built facilities yet still have a 50-plus year life span and lower maintenance costs compared to relocatable buildings. 434 Facilities Management Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 435 3.9 Facilities Improvement and Modernization Professional Standard The LEA manages and annually reviews its five-year deferred maintenance plan and verifies that expenditures made during the year are included in the plan. Effective July 1, 2013, Assembly Bill 97 repealed State Allocation Board apportionment authority for the Deferred Maintenance Program and provided for the governing boards for each school district to have full local control over deferred maintenance expenditures, earnings and funds. This standard is no longer applicable under current law and will be eliminated from the evalua- tion process and scoring rubric. Standard Not Applicable July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: N/A July 2016 Rating: N/A July 2017 Rating: N/A July 2018 Rating: N/A July 2019 Rating: N/A July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: N/A July 2022 Rating: N/A July 2023 Rating: N/A 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 436 Facilities Management 3.10 Facilities Improvement and Modernization Professional Standard The LEA’s staff are knowledgeable about procedures in the Office of Public School Construction (OPSC) and the Division of the State Architect (DSA). Findings 1. In 2021, the district hired a deputy chief maintenance and operations officer who has many years of experience working with state agencies such as OPSC, CDE, DSA, as well as local governmental agencies and has been overseeing facilities planning and construction functions. This officer has provided the required professional leadership to guide the district’s construction, engineering and architectural projects, legal claims avoidance practices and can work on multiple projects effectively and simultaneously at varying stages of completion. Approximately six months ago, a deputy chief facilities planning and construction officer was hired. The facilities-related oversight duties are now divided between the two positions. Going forward, the new deputy chief facilities planning and construction officer will provide the professional leadership to guide the district’s construction, engineering and architectural projects, legal claims avoidance practices, and manage the work of facility projects at all stages from planning to completion. 2. The hiring of the deputy chief facilities planning and construction officer has provided additional capacity for the responsibilities beyond maintenance and repair and should improve the district’s organizational capacity while preforming project management more effectively. This new staff member was required to possess, at a minimum, knowledge of construction project management, delivery methods, construction legal claims avoidance practices, and management of all necessary consultants, including but not limited to funding, architec- tural, engineering, and construction delivery practices. The job description states that the deputy chief facilities planning and construction of- ficer is responsible for giving input on preparing the districtwide capital project budgets to provide the most cost-effective facilities plan to meet district construction needs within established timelines. This position is also responsible for coordinating the work of district staff, commercial realtors, financial consultants, and others in the successful completion of assigned projects. In addition, this position is responsible for directing, supervising, and formally evaluating the work of the staff under their direction. The deputy chief facilities planning and construction officer position also includes duties of planning, coordinating, organizing, directing, supervising, and managing the district’s new comprehensive Facilities Master Plan as it relates to construction, modernization, re- modeling, and reconstruction of facilities within the district and will be key to managing the district’s rightsizing efforts. Facilities Management 437 3. The deputy chief maintenance and operations officer is experienced, knows the actual needs of the district and can be of great assistance to the district’s facilities planning and construction efforts. Interaction and communication between maintenance and operation administration and the deputy chief facilities planning and construction officer will be key. The responsibility lines between departments need to be well defined and the two departments need to work together closely to successfully meet both construction and operational needs of the district. 4. The district lacks support staff members who are well versed in OPSC and DSA procedures creating a need/dependence on outside consultants and needs to provide training opportunities to increase knowledge in this area. 5. The district’s capital facilities projects cost accounting is performed and managed in its Fiscal Services Department. However, when state funds are involved, the deputy chief facilities planning and construction officer will need to help develop accounting documentation to properly account for and close the project through state audits. Recommendations for Recovery 1. The district should maintain the management position(s) as needed to support the departments responsible for facilities construction maintenance, and operations and to provide leadership, manage facility needs, work with state and local agencies, and oversee related staffs. In addition, the responsibility lines between departments need to be clearly defined to facilitate the departments working together. 2. Due to the need for knowledge and experience, the individuals hired in the facility management positions should be required to maintain current knowledge of facility requirements, working with state and local agencies, facility construction, and of school facility maintenance and operations. 3. As facilities maintenance and construction activities increase, further support staff may be needed in these departments. If additional support is needed, the district should seek to hire permanent staff; an investment will be required to attract, train and retain qualified individuals. 4. The district should also consider succession planning for all leadership positions to avoid a loss of district facility knowledge if staff retire or otherwise leave the district. 5. Rather than continually seek consultant support, the district should seek ongoing education and experience in working with OPSC and DSA from organizations such as CASBO and CASH. The district should network with experienced staff in other school districts of similar size and demographics to help navigate the school construction regulations and funding options. The county office of education can also help and serve as one of these network partners. 438 Facilities Management 6. The district’s Fiscal Services Department should continue to perform accounting for the district’s facility projects. The new deputy chief facilities planning and construction officer will need to work closely with the Fiscal Services Department staff to ensure proper accounting is set up for each project and to manage reporting and state audits. The district, along with the new deputy chief facilities planning and construction officer, should identify a team responsible for applying for state funding eligibility and for reporting expended funds as required by OPSC. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 0 July 2015 Rating: 2 July 2016 Rating: 4 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 5 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 439 4.1 Construction of Projects Professional Standard The LEA maintains a staffing structure that is adequate to ensure the effective management of its construction projects. Findings 1. The district’s staffing that oversees and manages construction projects consists of the deputy chief facilities planning and construction officer, deputy chief maintenance and operations officer, CBO, and senior executive director of fiscal services. 2. Leadership in the district’s facilities, maintenance and operations has been stable since the hiring of the deputy chief maintenance and operations officer in 2021. The district recently hired a deputy chief facilities planning and construction officer. 3. Since starting in 2021, the deputy chief maintenance and operations officer has shown significant improvements in the district’s properties and an effective management of maintenance and repair projects. With the addition of the deputy chief facilities planning and construction officer, significant progress is expected in addressing the district’s facility needs. 4. The deputy chief maintenance and operations officer has extensive experience, knowledge, and the ability to manage the duties of maintaining and repairing the facilities. Under this position, the district has made numerous facility improvements within a limited budget and time constraints. These efforts have resulted in significant improvements in the appearance, safety, and functionality of the district’s facilities, and progress has been made in some of the district’s construction projects. 5. Due to lack of sufficient staffing with knowledge and experience, the district has employed an outside construction consultant to meet its project management needs. The new deputy chief facilities planning and construction officer should fill this project management need in the future as he assumes his full responsibilities, but consultants may be necessary in the meantime. 6. During this review period, the district has made progress on several projects (see Standard 3.1). 7. The district continues to face substantial school improvement project needs throughout the district. The FMP supports effective management of facilities projects by providing a prioritization of facility needs and a roadmap for addressing them. 8. Maintenance and operations staff still appear to have limited input on the district’s projects. As these projects are being designed, this input is essential so that the wear and maintenance may be considered from the beginning. 440 Facilities Management Recommendations for Recovery 1. As changes in staffing occur, the district should ensure that the organizational structure has clearly defined roles and lines of authority to manage facilities and related projects. The structure should include positions responsible for project planning, decision- making, purchasing and bidding procedures, budgeting and accounting for project funds, maintaining project records, approving change orders, agency reporting and communication at various levels. 2. The district’s deputy chief maintenance and operations officer and deputy chief facilities planning and construction officer positions should only be filled by persons who have extensive knowledge and experience in construction management as well as leadership, project management and communication skills. 3. The district should make every effort to retain knowledgeable staff, including investing in the training needed to effectively do their job. Whenever a vacancy occurs, the district should invest in attracting a highly qualified and experienced individual. 4. The district should consider staff succession planning for future leadership position needs so that gaps in qualified staffing, which greatly affect progress, are minimized. 5. While developing internal staff capacity and stability, the district should continue using consultants where needed so that facility improvement progress continues. Consultant use may be needed for special projects and to maximize funding applications that are not frequent enough to establish district expertise. 6. The district should continue to look for appropriate facility related funding sources including any federal, state or LAWA funding. The district should continue to maintain accounts for bond, federal, LAWA, and state-funded projects separately to allow for individual project identification, reporting and accountability. These expenditures reports should be available for review as necessary and should be comprehensive, including information from the first to the final expense. Individual project reports should span multiple years and be available for review as necessary. 7. The district should maintain, review and update its FMP regularly to ensure it is accurate and serves as a relevant guide to meet the district’s facility needs. 8. The deputy chief maintenance and operations officer or designee should be given opportunity to provide input in the design phase of projects so that wear and maintenance considerations can be understood from the beginning. Facilities Management 441 Standard Partially Implemented July 2013 Rating: 1 July 2014 Rating: 1 July 2015 Rating: 1 July 2016 Rating: 5 July 2017 Rating: 4 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 5 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 442 Facilities Management 4.2 Construction of Projects Professional Standard The LEA maintains appropriate project records and drawings. Findings 1. The district still does not have documented processes and procedures to ensure appropriate and consistent file retention of facility and construction records. The district lacks clear and established practices that include developing and maintaining a defined policy handbook for records retention. Such a handbook should include roles and responsibilities of maintenance staff and a process to routinely evaluate the records retention procedure and its implementation. 2. In response to FCMAT’s question regarding the location of records, the district responded that the facility “physical files are located in the Business Services Office at 401 S. Inglewood Ave. Inglewood CA 90301” and the “construction project files are located in a Google shared drive, District Office and Maintenance Department.” 3. The records retention facility should hold records related to all past and present construction projects permanently, including bid documents, state school facility records, and architectural drawings. Since new construction projects are taking place, the district should pack, label, and permanently retain older records and replace them as updated records are available. This process is a permanent and ongoing process needed by the district. Records retention is accomplished using different retention methods and in multiple areas, which make it difficult to ensure a full set of records is maintained. In addition, the physical storage areas are not sufficiently protected from potential fire or water damage. School facility plan history is important for the district to retain for future maintenance and improvement projects and will save the district valuable time and money. 4. Although there is no documented process, FCMAT found that records are organized by the school site and are easy to locate. The district has also implemented a checkout system for users who requested to view or check out the physical documents. Staff reported that this practice continues. Staff also indicated these practices are intended to continue with the new construction documents, and that most recent records and drawings are also delivered and archived in electronic format. 5. District staff confirmed that many records continue to be accessible to maintenance staff and the deputy chief facilities planning and construction officer via electronic file. Work order repairs and changes to existing building systems and drawings continued to occur. In those instances, records are difficult to get documented and updated. A great deal of knowledge of the district’s sites and facilities have appeared to be tied to outside consultants and contractors. The district stands to lose irreplaceable institutional knowledge when staff leave the district unless project records and drawing files have been kept, organized, stored and are readily accessible. Facilities Management 443 Recommendations for Recovery 1. The district should develop and implement a required processes and procedures handbook for the district’s file retention library. This process should be maintained and monitored by district administration to ensure it is followed. 2. The district should continue to maintain the facilities and construction records in an organized manner. Plans and specifications, contract documents, and materials specifications should be maintained indefinitely. The district should ensure the records are secure and reasonably protected from destruction. Back up and/or electronic files should be kept ensuring the records are not lost. 3. Electronically stored records should require processes to ensure they are always available as technology continues to evolve. This will require regular updates of software and possibly hardware. The district should create an electronic directory with cross- referencing for the facility records repository indicating the exact records available and their location. The directory, preferably electronic, should be detailed and cross-referenced so it can be searched and accessed easily by district staff. 4. The district should consult with facilities, maintenance and operations leadership as well as legal counsel to determine which documents are required for permanent records retention. The district should never purge documents without first ensuring it is proper to do so. 5. A system should be developed to ensure all project architects and contractors provide all necessary documents for each project, preferably in a district-approved electronic format. The district should define this requirement, and it should be included in the construction contract’s general conditions in future construction contracts. During construction, monthly contractor’s payments should be held until current marked up as-built drawings are delivered (“as-built drawings” refers to architect plans that have notes and edits to indicate construction details if different from the original plans). This requirement should also be made of the architect of record and verified daily by the state inspector. If a construction management firm is used as a delivery method, this consultant should be held to the same accountability for documenting as-builts for completeness. Final payments should be held from each architect and contractor until this information is confirmed and given to the district. If a general contractor is used on projects, the district should require the architect and any consultants to verify the information with the state inspector and to ensure the drawings are complete. 6. The district should annually evaluate the document retention processes including electronic storage software. Continued updating of software and saved files may be required so the district’s facility and project records are secure, accessible, and readable. This process should never conclude and may require periodic review by a third-party architect to evaluate the district’s ongoing records management process. 7. The district staff should take project pictures of all work that is to be concealed, including underground utilities and piping, before walls are enclosed, etc. This process should be mandated by the administration and carried out routinely on each project. These photos should be labeled and stored accordingly. If possible, photos should include dimensions for further clarity. 444 Facilities Management 8. In addition, these images should be added to the electronic library filing system for future access by work crews and contractors during any maintenance, modernization, and new construction projects. 9. The district should create a policy to allow original paper documents to be removed only when necessary and when no other option exists. No outside people should be allowed to handle documents unless they are bonded, district-approved vendors capable of handling the documents and process. 10. Bonded printing contractors should always handle paper originals at the district site, and the district should never allow private firms to take documents. Contractors should only identify the documents they require to finish the projects they are contracted to complete. This policy should also consider allowing only the release of electronic copies. This policy should have no exceptions. 11. The district should maintain a paper printer so that copies can be printed from electronic files to scale for use by workers and contractors in the field. District staff should make notes and sketches on prints that then should be documented into the existing file. This process is typically a difficult process to maintain, so the district should determine a reasonable and workable process to fit the needs of both the district’s retention requirement and the workers’ need for records. Standard Fully Implemented July 2013 Rating: 8 July 2014 Rating: 8 July 2015 Rating: 9 July 2016 Rating: 9 July 2017 Rating: 9 July 2018 Rating: 9 July 2019 Rating: 9 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 9 July 2022 Rating: 9 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 445 6.1 Facilities Maintenance and Operations Legal Standard The LEA is in compliance with requirement of the Williams case settlement. The governing board provides clean and operable flush toilets for students’ use; toilet facilities are adequate and main- tained. All buildings and grounds are maintained. (EC 17576, 17592.70-17592.73, 35186; CCR Title 5, Section 631, Section 4683, Section 14030) Findings 1. LACOE conducted eight facilities inspections required under the Williams Act between February 2022 and April 2022 using the Facilities Inspection Tool (FIT). Six of the schools reviewed received overall ratings of good and two received exemplary ratings. The district performed preinspections on the sites to be inspected by LACOE but did not conduct facilities inspections on school sites not visited by LACOE. 2. See Standard 1.8 for supporting detail on restroom cleanliness. 3. The district’s routine restricted maintenance account (RRMA) budgeted $6,015,006 for the 2022-23 fiscal year, this includes allocations for staff, repairs, parts and contracted services. This amount exceeds the required contribution of $4,523,475.48. 4. FCMAT’s site visits found that Morningside High School had a natural gas leak that caused the site to be vacated for multiple days while repairs were made. 5. Due to declining enrollment, the district’s overall facilities capacity is significantly more than what is needed to house its total student enrollment. As a result, the district must maintain an excessive number of facilities. In addition, much of the facilities are old and in disrepair causing the burden of maintenance to be extensive. 6. The district’s Maintenance, Operations and Transportation Department staffing is inadequate for the overall size of district facilities and grounds that needs to be maintained. 7. Since the district cannot address all work orders, those generated because of unsafe or unsanitary conditions receive priority in the SchoolDude work order system. 8. The district has the equipment and supplies needed and available to effectively maintain and clean the sites. 9. FCMAT’s visit found that only one principal provided feedback to custodians using a form titled Buildings and Grounds Inspection Checklist. This document allows the principal to monitor and give feedback on services received including restroom, offices and cafeteria cleanliness. 10. FCMAT’s field visits concluded that overall restrooms were not routinely inspected, stocked with paper and soap products and cleaned. 446 Facilities Management Recommendations for Recovery 1. The district should ensure facilities inspections are conducted as required by the Williams Settlement. 2. The district should conduct facilities inspections at all school sites not covered by the LACOE inspections and use the FIT form to perform the inspections. 3. The district should adequately fund its Maintenance, Operations and Transportation Department budget to meet statutory funding requirements and ensure adequate maintenance of its school sites as required under the Williams legislation. 4. The district should continue to monitor the inventory of maintenance and cleaning equipment, including pressure washers, to ensure that equipment is available as needed. 5. When students and staff are on sites, the district should continue to require frequent daily inspections of all restroom facilities to ensure they are accessible, clean, stocked, and in proper working order. 6. The district should encourage all principals to regularly provide feedback to custodians using the form titled Buildings and Grounds Inspection Checklist. A copy should be retained by the principal and another shared with the deputy chief maintenance and operations officer to accumulate data to be used in custodial evaluations. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 5 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 6 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 447 6.2 Facilities Maintenance and Operations Legal Standard The LEA has established the required account for ongoing and major maintenance. (EC 17014, 17070.75) Findings 1. The district’s 2022-23 annual adopted budget included a total RRMA budget of $6,015,006, which exceeds the amount required under EC 17070.75. 2. The CBO indicated that at the end of the 2021-22 fiscal year, the RRMA was not fully expended. However, the CBO reported that based on spending patterns, the RRMA will be fully expended for the 2022-23 fiscal year. 3. The deputy chief maintenance and operations officer has a high level of expertise in school facility maintenance and during his short tenure has implemented many facility and grounds repairs throughout the district. This position is exercising authority over the maintenance and operations budget and allocating funds to complete projects. 4. Every site visited by FCMAT had facility maintenance needs. 5. As of January 2023, approximately 42% of the fiscal year remained, yet many of the maintenance and operations accounts were found to be over drawn. Specifically, in the RRMA budget, objects 4310, 4317, and 5630 indicated a negative budget. 6. In the past, the district provided FCMAT with a multiyear plan for preventive and deferred maintenance; however, no documents to support this area were provided for this or the prior review period. While the state no longer requires a deferred maintenance plan (see Standard 3.9), best practices dictate that the district develop and maintain a current plan for maintenance needs and budget adequate funds for those needs to prevent more expensive repair work in the future. The deputy chief maintenance and operations officer has the skills to help develop and budget this plan. 7. In previous review years, the Facilities, Maintenance, Operations and Transportation Department staff stated they had the opportunity to review planned capital facility projects and had recommended various types of infrastructure related repairs or maintenance to take place at the same time as the capital projects. However, there is no evidence that the maintenance staff provided input into facilities planning for capital projects during the past two review periods. 448 Facilities Management 8. The district continues to not fully use the PMDirect module of SchoolDude, which is intended to proactively schedule routine preventive maintenance work such as inspections and servicing of heating, ventilation and air conditioning (HVAC), roofing, and fire alarms. The district continues to address its maintenance issues reactively and lacks a budget and calendar for planned preventive maintenance projects that address the critical needs of major infrastructure related systems. Recommendations for Recovery 1. The district should continue its maintenance budget at an amount no less than necessary to meet the requirements of EC 17070.75, should consider funding to match the district’s maintenance needs, and should fully use the funding provided. Additionally, accurate funding estimates should be used when projecting needed budget allocations. 2. As a best practice, the district should update its five-year deferred maintenance and its preventive maintenance plans to include current facility conditions and needs even though the deferred maintenance program is no longer a legal requirement. 3. The district should be proactive and address projects identified in the comprehensive, multiyear preventive and deferred maintenance plans. 4. To ensure accurate budgeting and ensure full use of funds, RRMA budgets and actual expenditures should be tracked and align with the timeline of the fiscal year. If unexpected expenses or savings occur, adjustments reflecting them should be made to the budget. 5. Any position that is extended authority to oversee the routine restricted maintenance budget should be trained to read and understand the budget and its appropriate use. Those positions should have the authority and ability to allocate funds to appropriate projects and repairs. 6. The district should implement a multiyear maintenance and equipment replacement plan to ensure transparency, accountability, and make certain that funds are spent on the proper needs of the district. 7. The district should create a maintenance project list that identifies the need to repair or replace large, deferred maintenance items, such as roofs, pavement, underground utilities, boilers, HVAC units, and electrical systems based on life cycle costs. 8. The district should include maintenance staff in planning for capital projects to provide input on recommendations of infrastructure related repairs or maintenance to take place at the same time as the capital projects. 9. The Maintenance, Operations and Transportation Department should expand the use of the PMDirect module of SchoolDude to support preventive and deferred maintenance needs. Facilities Management 449 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 6 July 2016 Rating: 6 July 2017 Rating: 6 July 2018 Rating: 6 July 2019 Rating: 6 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 6 July 2022 Rating: 6 July 2023 Rating: 6 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 450 Facilities Management 6.3 Facilities Maintenance and Operations Professional Standard The LEA uses and maintains a system to track utility costs and consumption and to report on the success of its energy program in reducing the cost of utilities. An energy analysis has been com- pleted for each site. Findings 1. BP and AR 3511 were approved on February 20, 2019. This policy and regulation promote the effective use of the district’s fiscal resources through a resource management program. Minimizing utility costs is one of the strategies listed in the policy to implement effective and sustainable resource practices. To accomplish this, tracking utility costs and energy consumption is necessary. 2. The district does not use an energy management system (EMS) although it had implemented a limited computerized system in the past. 3. The district indicated that a comprehensive energy analysis was completed in the past. No recent analysis has been completed. The district also had indicated, previously, the intent to hire a part-time person to monitor utility costs and help change behavior regarding utility usage. This position has never been filled. 4. Measures GG and I include the goal and purpose to “upgrade of facilities for energy efficiencies.” The district has included energy efficient upgrades in its recent facility improvement and site consolidation projects. Recommendations for Recovery 1. The district should review and update BP and AR 3511 as needed to ensure they are current. 2. The district should assess the capability of its EMS and consider its repair or replacement to ensure it can support implemented energy conservation measures such as interior occupancy sensors, lighting retrofits and the latest air-conditioning systems. 3. The district should consider conducting a comprehensive energy analysis every five years to identify opportunities for energy and cost savings. 4. The district should develop and implement a process to track utility costs and energy consumption and comply with BP and AR 3511. This process should incorporate using the district’s utility providers’ online monitoring tools. These tools can include energy usage charts, demand response programs, and smart meters. With recent increases in natural gas and electricity cost, the district should implement a quarterly review to ensure utility budgets adequately support ongoing costs. 5. The district should ensure energy efficiency considerations are included in its bond- supported projects as identified in Measures GG and I. Facilities Management 451 6. The district should continue implementing energy conservation measures including interior occupancy sensors, lighting retrofits, and new HVAC equipment as opportunities arise. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 1 July 2022 Rating: 1 July 2023 Rating: 1 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 452 Facilities Management 6.4 Facilities Maintenance and Operations Professional Standard To safeguard items from loss, the LEA keeps adequate maintenance records and reports, including a complete inventory of supplies, materials, tools and equipment. All employees who are required to perform custodial, maintenance or grounds work on LEA sites are provided with adequate sup- plies, equipment and training to perform maintenance tasks in a timely and professional manner. Findings 1. The district continues to keep adequate maintenance records and has inventoried all the tools, materials, supplies and equipment that are stored at the maintenance and operations/central warehouse facility. The district continues to organize and improve the maintenance and operations/central warehouse facility with removal or discarding of unused or antiquated equipment. 2. Employees who perform custodial, maintenance, or groundskeeping work are generally provided with adequate supplies and equipment to perform their tasks in a timely manner. No marked delays to work were reported due to the availability of supplies or equipment. 3. During FCMAT field visits, it was observed that the district had recently changed financial management software. This change affected the way school sites ordered custodial supplies from a central warehouse. The district implemented the BEST financial management system that will ultimately allow sites to order custodial supplies electronically. At the time of field work, staff indicated that a “paper” system for requisitions of materials and supplies for school sites was being used. The paper system equates to email requests from sites, which are printed, and deliveries are signed for by the receiver. The senior storekeeper orders all supplies for the warehouse. The custodial supervisor oversees the fulfillment of the maintenance and custodial supply requisitions from the school sites. 4. FCMAT observed that most schools maintain a small number of custodial supplies at the sites, but they did not keep an inventory of the site-maintained supplies. 5. The district hired a new custodial supervisor in January 2021. The custodial supervisor, who was promoted from within the district, did not know about the IUSD Custodial Handbook. Since then, the custodial supervisor has received training with FRISK (employee accountability process) and supervisory expectations have been identified. 6. During the 2023 site visits, the district informed FCMAT that the custodial supervisor position was vacant. The district could not determine when and if the position would be filled. 7. During site visits, FCMAT observed that many sites have identified areas for the storage of custodial supplies. Many custodial closets have storage racks, and most were orderly and neat. This allows the custodial supervisor to secure yet quickly assess the contents and supplies. 8. The district has provided on the job and online training to maintenance and operations staffs in the safe and effective use of materials and equipment. Facilities Management 453 Recommendations for Recovery 1. The district should continue to maintain and keep current a computerized inventory system for all maintenance, operations and transportation supplies, tools, and equipment. These items should be organized and secured in a predetermined location at the warehouse. In addition, a schedule for replacement should be developed. 2. The district should continue to provide staff with adequate supplies and equipment to perform their tasks. 3. The BEST inventory module should be expanded, if possible, to school sites and networked with the central warehouse to support the direct ordering of supplies, communication of order status, as well as historical supply usage. 4. The BEST inventory module should be checked monthly, and a complete physical inventory count and reconciliation should be completed at least once per year to ensure count and value accuracy. 5. The district should continue to maintain a minimum inventory of custodial and maintenance supplies and equipment to support timely access to essential items based on the ordering information contained in the BEST inventory module. 6. The district should consider filling the vacant custodial supervisor position. A main responsibility of this position should be to hold custodians accountable for their work quality and quantity, as well as working safely and maintaining a safe environment for all staff and students. With the assistance of a custodial supervisor, sites can develop their own inventory for custodial supplies. The site administrator and the custodial supervisor should regularly review the inventory and should always have access to custodial closets as well as the ability to perform random audits of inventory. The district should develop standards for the amount of material a site maintains in stock based on the number of restrooms, the student population and historical use. The approval for ordering site custodial supplies should come from the school site administrator and be reviewed by the custodial supervisor. An inventory list should be maintained in each custodial closet. 7. The district should continue to provide all custodial, maintenance and groundskeeping employees with safety and effective use of materials and equipment training. Records of all trainings should be maintained and include name of instructor, topic, dates, and attendees. Additionally, if staff are provided equipment and trained to use it, the district should ensure staff implement it as intended. 8. The district should monitor the industry best practices for maintenance, groundskeeping and custodial trades and provide equipment and training based on those professional practices to ensure that the district uses techniques that are the most effective and efficient. 9. The district should consistently implement action plans to help custodians improve cleaning, sanitization, and disinfection procedures. These documents can be useful in conducting annual evaluations. 454 Facilities Management Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 2 July 2016 Rating: 2 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 5 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 5 July 2022 Rating: 5 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 455 6.5 Facilities Maintenance and Operations Professional Standard Procedures are in place for evaluating the quality of the work performed by maintenance and operations staff, and evaluations are completed regularly. Findings 1. The district has BP 4215 for evaluating the quality of work performed by the classified staff. This policy was adopted in 2014 and no revisions are noted. 2. The district maintains an organizational chart for the Maintenance, Operations and Transportation Department that identifies supervisory and reporting relationships. Due to constantly changing staffing, the organizational chart requires regular updating. 3. Site administrators evaluate the custodians, and the deputy chief maintenance and operations officer offers supportive input into those evaluations. Discussions with site administrators indicated there was inconsistency with annual evaluations and they have not always been completed annually. Additionally, the district did not provide a listing of evaluations completed or examples of any completed evaluations. 4. Classified employees recently approved joining a new labor union. The current collective bargaining agreement requires that the members with permanent status be evaluated annually. 5. The deputy chief maintenance and operations officer is responsible for overseeing all aspects of maintenance, operations and transportation. Recommendations for Recovery 1. The district should review and revise BP 4215 as needed to ensure it remains appropriate and applicable. 2. The district should follow its adopted policy for the evaluation of classified staff including those in maintenance and operations. Evaluations should be completed according to district timelines. The HR Department should monitor evaluations and ensure they are completed as prescribed and align with collective bargaining agreements. The HR Department should verify that the appropriate signatures are on each evaluation. 3. The district should continue to review and maintain its organizational chart for the Maintenance, Operations, and Transportation Department and update it as changes are made. This information should be distributed to all sites and affected personnel in the district. 456 Facilities Management 4. The district should complete its annual custodial evaluations, with the site administrator having primary responsibility for their completion, and the deputy chief maintenance and operations officer and custodial supervisor providing input as needed. The deputy chief maintenance and operations officer, has technical expertise that can ensure accurate and constructive evaluation of work. Site administrators can address overall satisfaction and soft skills, such as communication, interaction with staff and responsiveness. 5. The district should determine the proper span of control for the deputy chief maintenance and operations officer to ensure responsibilities are reasonable and adequate supervision is provided. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 4 July 2018 Rating: 6 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 457 6.6 Facilities Maintenance and Operations Professional Standard The LEA has identified major areas of custodial and maintenance responsibility and specific jobs to be performed. Written job descriptions for custodial and maintenance positions delineate the major areas of responsibility for each position. Findings 1. The district updated its 2022-23 organizational chart for the Maintenance, Operations, and Transportation Department in December 2022, but due to frequent staffing changes, it was quickly outdated. For example, as of January 2023, the custodial supervisor position was vacant. The district could not identify when the position would be filled. The board approved organizational chart shows the chief deputy maintenance and operations officer overseeing the Maintenance, Operations, and Transportation (MOT) Department. 2. FCMAT was not provided job descriptions; however, the district’s website does maintain a list of job descriptions. The job descriptions on the website do not indicate when they were board approved or updated. The Americans with Disabilities Act permits employers to define a job and the functions required to perform it, including qualifications and work quality and quantity standards. Although the Americans with Disabilities Act does not require written job descriptions, having these before advertising or interviewing applicants is strong evidence of whether a particular job function, such as driving, is considered an essential function. Therefore, keeping job descriptions current and listing all essential job functions is vital in managing the risks of Americans with Disabilities Act claims. 3. The district developed the IUSD Custodial Handbook in January 2017 that identifies cleaning methods and performance standards for custodial positions. The handbook is available in its original form on the district website under the Facilities, Maintenance, Operations and Transportation Department section. In previous years, staff reported that all custodial staff had received this handbook and had been trained in its content. During site visits recent and past, FCMAT received a mixed response from both principals and custodians about the availability of the handbook, indicating new site administrators and custodians had not been informed of the existence or trained on the content of the handbook and further, that the handbook is not being used with consistency. 4. The district maintains a form titled Buildings and Grounds Inspection Checklist. This document can be used by site administration to monitor and give feedback on services received including restroom, offices and cafeteria cleanliness. 5. The district does not have a handbook for maintenance and groundskeeping personnel that identifies maintenance strategies, performance standards and organizational structure. 458 Facilities Management Recommendations for Recovery 1. The district should routinely review and update its organizational chart for the facilities, maintenance, operations, and transportation departments. This should be shared with site staff to ensure that problems, concerns, recommendations, or commendations are communicated through the proper chain of command. 2. All maintenance and custodial job descriptions should be reviewed, updated, board- approved and published in a standardized format. Job descriptions should reflect the county administrator/board approval and/or revision date, the essential functions, roles, tasks, and supervisory responsibilities under the current organizational structure. 3. The district should continue using the cleaning methods and performance standards identified in the IUSD Custodial Handbook as part of employee evaluation criteria. The IUSD Custodial Handbook should be regularly updated with up-to-date best practices and employees trained accordingly. 4. The district should review the Buildings and Grounds Inspection Checklist with site administrators and encourage them to regularly use this form to help monitor site custodial staff and to ensure custodial services are satisfactory. In addition to sharing the form with the site custodians, a copy should be retained by the principal and another shared with the deputy chief maintenance and operations officer to accumulate data to be used in custodial evaluations. 5. Custodian schedules should be detailed, outlining normal tasks, describing each facet of the task and assigning an allotted time to each task. Additionally, substitute custodians will be able to follow these types of schedules with limited instruction. Custodial schedules should be reviewed regularly to ensure an equal distribution of the custodial workload. 6. The district should develop a maintenance and groundskeeping handbook. This will ensure staff is aware of performance standards and provide a basis for performance evaluations. Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 4 July 2019 Rating: 4 Facilities Management 459 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 460 Facilities Management 6.7 Facilities Maintenance and Operations Professional Standard The LEA has an effective written preventive maintenance plan that is scheduled and followed by the maintenance staff and that includes verification of work completed. Findings 1. The district does not have a written preventive or routine maintenance plan. An effective preventive maintenance plan includes major system components such as painting, electrical and technology upgrades, HVAC servicing, roofing, flooring, asphalt resurfacing, and plumbing repair. 2. The district does not maintain a schedule for repairing or replacing infrastructure equipment. As a result, facility modernization projects may not consider the upgrades of critical components needed to meet current educational delivery demands. 3. The work order system allows for the reporting of issues that require the Maintenance, Operations and Transportation Department’s attention. The maintenance supervisor assigns daily work orders to the maintenance staff based on immediate site needs. FCMAT’s review of preventive maintenance work orders found the district continues to be reactive rather than proactive in preventive maintenance. This is likely to continue until the district right-sizes its facilities and/or otherwise catches up with facilities maintenance work. 4. During the 2022 review, the work order system had approximately 44 work orders open or pending and documentation provided to FCMAT indicated that many work orders were completed in a timely manner. Site administrator interviews for that same period indicated that the maintenance staff was responsive to most work orders but follow up phone calls or emails were sometimes required to help expedite some repairs. A significant reduction was made in open or pending work orders as compared to previous review periods (e.g., 450 identified in 2018-19 and 158 identified in 2020-21). Facilities Management 461 5. During this year’s review, the number of open work orders increased significantly. Documentation indicated a total of 938 open work orders at the time of FCMAT’s fieldwork. 6. In 2016, the district implemented SchoolDude, which became the active computerized work order system. Principals report they have access to the system and are comfortable navigating through the program. Principals also report that they routinely upload pictures to the work order requests to provide clarification. 7. The district has subscribed to the preventive maintenance module, PMDirect, in the SchoolDude program, but there is no preventive maintenance plan. The district does not use the preventive maintenance module to generate work orders for recurring maintenance tasks before they become areas of need or even emergencies. 8. The deputy chief maintenance and operations officer continues to identify and address longstanding needs at the sites and throughout the district. The district provided FCMAT a 2022-23 Completed Projects List. Projects completed addressed a variety of health and safety issues including termite fumigation, flooring replacement, and fire alarm upgrades. External contractors completed all the projects on the list. Recommendations for Recovery 1. The district should develop a written, comprehensive, and proactive preventive maintenance plan that includes identified annual preventive maintenance projects, service intervals, long-term repair and replacement schedules, and costs to be included in the Fiscal Stabilization Plan. The preventive maintenance plan should be reviewed and updated annually and include budget allocations to support the plan. 2. The district should establish a system of evaluating the need to repair or replace infrastructure equipment based on age, repair frequency, cost to repair, and replacement cost. The district should regularly budget for the repair and replacement of necessary facilities equipment. 3. Maintenance, Operations and Transportation Department work order review procedures and prioritization should be established and communicated to maintenance staff and site administrators. After work orders are completed, they should be electronically signed by the employee performing the work and the site principal, as well as reviewed by the department head for timeliness, efficiency, and cost. The district should review its organizational structure and budget to determine if additional staff can be added to help complete maintenance work orders. 4. The district should continue the use of the SchoolDude work order system and continue to provide training to all district maintenance and applicable site personnel in its use. 5. The district should be diligent in its efforts to right-size the district to reduce work on nonessential facilities and sites. 462 Facilities Management 6. The district should implement the use of the PMDirect preventive maintenance module to generate work orders for recurring maintenance tasks. The district should include a list of regularly scheduled preventive maintenance tasks in the system to include items such as testing emergency lighting, roof examinations, cleaning roof gutters, clearing storm drain inlets, and cleaning and repair of equipment. Work orders should be regularly reviewed and analyzed to identify recurring needs, and these needs should be incorporated into maintenance project planning. 7. The district should consult with maintenance, groundskeeping, and site custodial staff when developing a preventive maintenance plan and facility modernization projects. Employees in these departments have historical knowledge and/or site-specific awareness of critical components that need replacement and maintenance. Standard Partially Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 1 July 2016 Rating: 1 July 2017 Rating: 1 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 2 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 463 6.8 Facilities Maintenance and Operations Professional Standard The LEA has planned and implemented a maintenance program that includes an inventory of all facilities and equipment that will require maintenance and replacement. Data should include estimated life expectancies, replacement timelines, and the financial resources needed to maintain the facilities. Findings 1. No evidence was provided of efforts made towards satisfying this standard since the 2019 review. 2. FCMAT’s site visits and interviews with staff reflected a variety of facility and equipment needs. 3. The district has not implemented a proactive preventive maintenance plan. The district departments over facilities, maintenance, operations and transportation operate in a reactionary mode, resulting in the maintenance staff’s inability to keep up with the decay, affecting district operations. 4. Previously, the district had developed a detailed inventory by site, including building square footage, site acreage, quantity of landscape turf, and quantity of asphalt. These documents were not provided for this review, so it is unknown if the district regularly updates this information. 5. The district does not maintain an equipment replacement schedule. 6. The district does not complete, at minimum, a biennial physical inventory and reconciliation. Recommendations for Recovery 1. The district should develop and implement a proactive preventive maintenance plan. 2. The district should inventory and track all capital items that have a useful life of one year or more and have a value of $500 or more. In addition, an extensive physical inventory should be completed every two years, ensuring the master inventory list is accurate. Asset tags should be placed on appropriate units at the time of delivery to the district warehouse and before distribution to the individual sites or departments. 3. The district should ensure that it annually updates its detailed inventory of buildings, including building square footage, site acreage, major equipment installation dates (e.g., HVAC units and electrical equipment), quantity of landscape turf, and quantity of pavement. 464 Facilities Management 4. The district should develop a replacement schedule for all its equipment. The district should annually budget for the replacement of necessary equipment based on the replacement schedule it develops. Standard Not Implemented July 2013 Rating: 0 July 2014 Rating: 0 July 2015 Rating: 0 July 2016 Rating: 0 July 2017 Rating: 2 July 2018 Rating: 2 July 2019 Rating: 2 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 2 July 2022 Rating: 2 July 2023 Rating: 0 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 465 6.9 Facilities Maintenance and Operations Professional Standard The LEA has a documented process for prioritizing and assigning routine repair work orders. The LEA has a work order system that tracks all maintenance requests, the employee assigned, dates of completion, labor hours and the cost of materials. Findings 1. In October 2016, the Facilities, Maintenance, Operations and Transportation Department began using SchoolDude as the district’s work order system. The district has fully embraced the use of SchoolDude; however, staff reported during the 2021 review, that the district was considering moving to another work order system. 2. During the 2023 review, interviews indicated the district is continuing to use SchoolDude and is not considering a change to another system. 3. The district has provided training for the use of SchoolDude to principals, vice principals, office managers, and maintenance staff in the past. 4. The Maintenance, Operations and Transportation Department administrative secretary electronically organizes work orders, and the maintenance supervisor assigns them daily to the maintenance staff. The deputy chief maintenance and operations officer monitors this process and will prioritize and reassign work based on emergency or technical expertise needed to complete a specific work order. 5. Previous reviews reported that the maintenance staff had been issued electronic tablets, which replaced the need to print work orders. Maintenance staff does not consistently document information on work orders such as the amount of time spent on a project, the cost of materials or a description of the work completed. 6. The SchoolDude work order system can be updated in real time. Interviews with site principals indicated that updates with details about assigned work orders are not regularly completed. Principals also indicated they do not sign off on the work orders once completed but can check the work order system to determine the status of a work order request. Because of infrequent updates, this information is not reliable. Site administrators reported that the deputy chief maintenance and operations officer routinely makes site visits and there is effective communication on work order status. 7. Principals reported that most work orders are addressed in a timely manner. 8. Vandalism and/or tagging is tracked in the work order system. This allows the district to accurately determine how much effort in time and materials is expended to address this work. Site and department staff interviews indicated these tasks regularly divert them from scheduled work. During site visits, FCMAT learned that the district prioritized 466 Facilities Management responding to vandalism and tagging. Staff reported that the first task every day was to address any tagging that occurred the prior night. 9. During the 2023 visit, FCMAT reviewed a list of open work orders. SchoolDude indicated there were 938 open work orders. This included requests for custodial supplies, so an accurate representation of the current maintenance requests was skewed. Additionally, the report included handwritten notes indicating that many of the work orders were complete and should be closed. This continues to indicate that the work order system is not updated in real time and lacks accurate information. Recommendations for Recovery 1. The district should continue to use the work order system consistently and increase the amount of information recorded. Work orders should be updated daily with information such as the status of the repair, parts or material used, and labor hours required to complete a work order. This should be done at least daily to ensure timely and accurate communication to site staff. This system would allow the departments responsible for facilities, maintenance, operations and transportation to better predict required staffing and fiscal budgets for the future. Updating the work order system in a timely manner will also help the district track productivity and costs and help prioritize and assign work. 2. The maintenance supervisor should continue to assign work orders. This allows the maintenance supervisor to monitor the types of repairs and work required at school sites. 3. Training on the use of SchoolDude should be offered regularly and required of new staff members to ensure the system is used effectively. 4. The Maintenance, Operations and Transportation Department should immediately communicate to school site administration when work orders are completed. This should be done electronically through the work order system and with face-to-face communication to allow site administration to verify the completion of work orders to their satisfaction. 5. The district should review its organizational structure and budget to determine if additional maintenance staff should be added to help complete maintenance work orders and to ensure work orders are completed in a timely manner. 6. The district should implement policies and procedures to determine work order priority and estimated completion dates as part of the feedback to school sites. 7. The district should consider tracking and creating a report for vandalism and tagging work orders by site, location on sites, types of vandalism and occurrence. Facilities Management 467 Standard Partially Implemented July 2013 Rating: 2 July 2014 Rating: 2 July 2015 Rating: 4 July 2016 Rating: 4 July 2017 Rating: 5 July 2018 Rating: 5 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 4 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 468 Facilities Management 7.2 Instructional Program Issues Legal Standard The LEA has developed and maintains a plan to ensure the equality and equity of all of its school site facilities. (EC 35293) Findings 1. BP 7110 was originally adopted in 2014 and last revised in February 2019. This policy states that one component of the FMP should be the: Analysis of the safety, adequacy, and equity of existing facilities and potential for expansion, including the adequacy of classrooms, school cafeterias and food preparation areas, physical activity areas, playgrounds, parking areas, and other school grounds. 2. BP 7110 authorizes the development of a facilities master plan based on district needs and aligned with the district’s goals for the instructional program. In 2015, the district prepared and approved a FMP that addressed facility conditions in relationship to educational program development. The plan contained a comprehensive inventory of attributes for each of the district school sites, the available facilities and plans for their improvement. It also included a comparative assessment of the sites and their existing needs across a range of areas, such as flooring, electrical, computing capacity and other quantifiable metrics. 3. During interviews, the district stated a new FMP had been completed and approved. Although requested, no finalized plan has been shared with FCMAT. However, under the district’s Facilities, Maintenance, Operations and Transportation webpage, there is a link titled Facilities Master Plan 2023. Following the link, a document titled Inglewood Unified School District Facilities Master Plan 2022 is found. This FMP Introduction section includes district historical background, mission and goals, district schools list and map, demographic trends, capacity analysis and enrollment trends. The current site conditions section, titled Ready from Day One, includes academic goals and performance, facility conditions, site and building conditions, functionality and health and wellness. And the Analysis and Recommendations section includes information by school site such as an overview of each site, existing conditions, proposed opportunities, and associated costs. 4. In early 2019, because of continued declining enrollment, the district drafted a plan for school closures, property surplus and facilities projects to balance the closure of some facilities, or reduction in used space, with the community’s needs. As of the time of FCMAT’s 2019 site visits, school consolidation had been addressed at two sites, and the district’s administrators were considering future consolidation. Facilities Management 469 5. On April 24, 2020, the district again refocused the type and scope of projects. The district provided FCMAT its Facilities Projects Implementation Plan and Budget for the 2019-20 fiscal year. The estimated budgets included funds from Measure GG, LAWA and other facility funds. This list contained many projects that were “on hold” or “TBD” (to be determined), as Measure I had not yet been approved, its funds had not been incorporated into the project plan and budget. On October 6, 2021, the district hired an architectural firm to develop a new FMP to assist the district in extensive short- and long-term facilities planning for its programs and school sites. During last year’s visit, the staff reported that an FMP was in development. 6. In November 2020, the district passed Measure I, which provides $240 million in general obligation bonds for future construction projects. As with Measure GG, the bond language identifies all district sites as eligible for improvements including school site health, safety, and security projects; renovation, repair, upgrade, and construction projects; wiring and technology for instructional support and learning projects; and other miscellaneous projects such as issues identified during construction, unforeseen conditions, rentals/ leases, and other work necessary to complete these projects. The passage of Measure I continues to demonstrate the community’s support in upgrading facilities. 7. During this review period, LACOE performed Williams Act inspections on eight of the district’s sites to identify conditions of sites and to support equity. The district should conduct inspections on the remaining sites. Throughout the years, the district has continued to suffer from a loss of enrollment and changing leadership in key decision-making positions. This continues to create a problem with changing priorities and continuity of information, which is evident in the number of times the district has “refocused” project types and plans for districtwide facilities. Recommendations for Recovery 1. The district should regularly review and update board policies related to facilities to ensure they reflect the latest equality and equity considerations. 2. The district should regularly review and update the FMP as required by BP 7110, which states: The master plan shall be regularly reviewed and updated as necessary to reflect changes in the educational program, existing facilities, finances, or demographic data.” When updating its Facilities Master Plan, the district should include the required components as follows: …Analysis of the safety, adequacy, and equity of existing facilities and potential for expansion, including the adequacy of classrooms, school cafeterias and food preparation areas, physical activity areas, playgrounds, parking areas, and other school grounds. (BP 7110) 470 Facilities Management 3. In expending the funds from Measure GG and Measure I outlined in the scope of projects identified in the bond language, the district should organize and prioritize the projects to maximize attendance areas and physical capacity of each site, and account for decreasing enrollment projections before using funds to enhance school sites. 4. The district should inspect all sites to ensure compliance with the Williams Act legislation. Each site should include that information in their respective School Accountability Report Card (SARC) to ensure that facility deficiencies are identified. 5. The district should consider the FMP a long-term facility plan that includes equality and equity considerations and allows the district to consistently address its issues with fixed priorities and in consideration with expected future district facility needs. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 3 July 2019 Rating: 3 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully Facilities Management 471 7.4 Instructional Program Issues Professional Standard The LEA’s grounds are appropriately landscaped and maintained to enhance an educational envi- ronment. Findings 1. The district has implemented a team approach to groundskeeping duties in which teams are to visit sites routinely to maintain the grounds, landscaping, and gardening. Each employee in the Groundskeeping Department has been provided with a workday schedule that was updated for the 2022-23 fiscal year. 2. Principal interviews indicated varied satisfaction with the grounds/landscaping conditions at their sites. Most believe that the groundskeeping staff is inadequate to maintain the existing facilities at an appropriate level of care. There continues to be a lack of clearly delineated roles and conflicting responsibility between the district landscaping/ groundskeeping crew and site staff about who is responsible for removing weeds in flower beds, along buildings and fences, and in the cracks of hard surfaces. As a result, many of these weeds are left untouched. FCMAT observed mixed conditions at many of the sites, with many areas lacking any improvement from the previous year. Interior portions of the campuses continue to have weed-abatement issues. 3. Based on interviews, the reporting structure indicates the deputy chief maintenance and operations officer oversees a custodial supervisor, maintenance supervisor, transportation supervisor and an administrative assistant. Although span of control refers to the number of subordinates reporting directly to a supervisor, it may also refer to the number of departments a supervisor can reasonably manage. The deputy chief maintenance and operations officer position has management assistance in the maintenance and operations area of responsibility, but according to interviews, the gardeners and skilled maintenance specialists do not report to the maintenance supervisor rather they report directly to the deputy chief maintenance and operations officer. 4. The district continues to be plagued with thefts from the maintenance yard. Equipment and vehicles are routinely stolen, which has affected operational effectiveness. 5. During site visits, FCMAT observed the groundskeeping crew work not following the grounds schedule provided. Many site administrators indicated the groundskeeping team schedule was inconsistent. Administrators did not always know their schools’ scheduled day of service and indicated the schedule is routinely changed or adjusted without any notification. Site principal interviews indicated concerns with adequate staffing, proper training and an antiquated irrigation infrastructure. These conditions continue to prevent significant improvements in the district’s overall landscape condition. 472 Facilities Management 6. The district does not have an irrigation control system that aligns with BP 3510 Green School Operations, which has the goal of reducing irrigation water consumption. 7. During prior visits, FCMAT had observed a draft version of a Groundskeeping Handbook that identified and required a wide range of knowledge of horticulture, pest control, weed abatement, use of pesticides, landscaping methods and performance standards for groundskeeper positions. FCMAT has not been provided an update on the draft Groundskeeping Handbook in the last couple of years, indicating it may not have been completed nor implemented. Recommendations for Recovery 1. The district should regularly review and update board policies that support the education environment and establish district standards for grounds landscaping and maintenance. 2. The district should regularly review and evaluate the team-scheduling concept to ensure its effectiveness and develop and adopt minimum standards for grounds maintenance and team performance. 3. The district should clearly delineate responsibilities of groundskeeping crew and site staff to ensure all site grounds are adequately maintained and to support staff accountability. 4. The district should review its organizational structure and budget, along with the latest industry tools, to determine if groundskeeping staff and/or equipment should be adjusted to properly complete groundskeeping work. This review should evaluate and recommend an appropriate span of control that allows adequate supervision of the groundskeeping and skilled maintenance workers. 5. The deputy chief maintenance and operations officer should continue routine site visits and discuss issues with the site administration. In addition, those discussions should be memorialized via the work order system or through the School Inspection Report. This creates an audit trail to increase accountability in the Groundskeeping Department. The deputy chief maintenance and operations officer should modify the gardeners’ work schedules as needed to address individual site needs. Any changes to the groundskeeping schedule should be communicated to site administrators. 6. The equipment and vehicles for the traveling groundskeeping team should be clearly identified, specifically assigned, and securing methods implemented to safeguard it from loss. 7. The district should consider new water conservation landscaping designs at each of its sites to conform to BP 3510. A districtwide water conserving irrigation system should be evaluated and implemented consistently. Centralized irrigation control should be a foundation for this effort. 8. The district should use the work order system or the Buildings and Grounds Inspection Checklist to provide feedback to the groundskeeping staff regarding the condition of turf, irrigation, floral plantings, and pruning. Facilities Management 473 9. When determining the appropriate staffing level, the district should clearly identify the acceptable level of care to ensure the conditions on its campuses meet community standards and support the district’s educational mission. Example descriptions can be found using guidelines from the Association of Physical Plant Administrators. 10. The district should use local vendors, community colleges, and various online trainings and webinars to ensure groundskeeping personnel have up-to-date knowledge and skills. 11. The district should develop, distribute, and use a Grounds Maintenance Handbook to facilitate training and accountability among groundskeeping personnel. Once developed, all groundskeeper staff should receive this handbook and receive training in its content. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 5 July 2016 Rating: 4 July 2017 Rating: 4 July 2018 Rating: 5 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 4 July 2023 Rating: 4 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 474 Facilities Management 8.2 Community Use of Facilities Professional Standard The LEA has a plan to promote community involvement in schools. Findings 1. The district adopted BP and AR 1330 regarding the community use of facilities, and last revised them in April 2019. The district has also developed a Facilities Use Application and Facilities Use Agreement that has been updated since the last review period. Both these documents are available on the district website. 2. BP 1330 recognizes that district facilities are a community resource authorized for use by community groups if they do not interfere with school activities. The district has made district facilities available to responsible organizations, associations, and individuals of the community for approved and appropriate activities. 3. The district has resumed the community use of facilities following the COVID-19 recommendations provided by the Los Angeles County Public Health Department and the California Department of Education. 4. The district has continued to receive and approve requests for the use of its facilities from the public and maintains a list of all organizations that have submitted facility use requests. 5. During the last review, staff indicated the district had approved the use of commercial parking operations on the asphalt playground areas at Kelso Elementary and Morningside High School by the Inglewood Educational Foundation. Interviews with staff indicate this use still occurs regularly at both sites. It was noted in the previous report that this use is not allowed under Section #9 Prohibited Activities on the Facilities Use Application and the Facilities Use Agreement. A review of the application indicates that the district has now modified and included a section on page three of the application to allow for the community use of parking; however, on page six of the same application, under Facilities Use Rules and Regulations, item #9 Prohibited Activities, it still prohibits the use of parking in asphalt play areas. Similarly, the new application asks if a third party will perform parking services, which may conflict with Paragraph 15 of the district’s Facility Use Agreement regarding the Assignment, Subletting, and Subcontracting portion of the agreement. Recommendations for Recovery 1. The district should review BP and AR 1330 regularly and update as needed to ensure they are still compliant, accurate and applicable. The district should also review and update its Facilities Use Manual, Facilities Use Application, Facilities Use Agreement , and Fee Schedule as needed. Facilities Management 475 2. The district should continue to facilitate and promote community use of facilities and continue to make information available on the district webpage such as its Facilities Use Application and Facilities Use Agreement. 3. The district should continue to allow the community use of school facilities within the confines of the latest COVID-19 safety guidelines regarding the use of public facilities. 4. Use of facilities requirements should be regularly reviewed to ensure that community use does not encroach on school resources and prevent the district from achieving its own established goals and priorities, nor should they be exorbitant and limiting to community use. The district should also maintain community use facilities in good condition and make them reasonably available to the public. 5. The district should review and modify its Facilities Use Application and Facilities Use Agreement so it is clear as to whether parking in asphalt play areas is allowed, and if the parking operations can be performed by a third-party subcontractor. Standard Fully Implemented July 2013 Rating: 7 July 2014 Rating: 8 July 2015 Rating: 8 July 2016 Rating: 8 July 2017 Rating: 9 July 2018 Rating: 9 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 9 July 2023 Rating: 9 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 476 Facilities Management 9.1 Communication Professional Standard The LEA fully apprises students, staff and community of the condition of its facilities and its plans to remedy any substandard conditions. The LEA provides access to its facilities staff, standards and plans. Findings 1. The district continues to maintain an IUSD Progress Report tab in the Construction Projects section of the website; however, at the time of review FCMAT found the Construction Projects section had not been updated since 2021. Previously, the district also had links on each of its individual school site webpages titled Construction Projects, but the links, were not working when tested. 2. The district publishes an email-based and hard copied newsletter titled Facilities-At-A- Glance that is available via subscription as well as a Communication to Staff, Families, Community, available on the district website, which contains periodic updates on district facility project activities. 3. The district uses social media platforms such as Facebook, Instagram, and Twitter to provide periodic district information including updates on construction projects. 4. The chief business official has been making public presentations on the status of facilities and maintenance projects at regular district board meetings. 5. The district has held five meetings of its combined Measure I and Measure GG CBOC since February 2022. CBOC meeting agendas and minutes are posted on the district website, as well as public comment request forms and annual audit information. A review of the minutes available reveals an absence of any detail about what information was presented to the committee by the district other than who made the presentation. The minutes note that comments are made by committee members, but there is no detail of the comments or any other questions or concerns expressed during the meeting. 6. The district posts its most recent 2021-22 SARC information on the district webpage, which include the sections titled School Facility Good Repair Status and Deficiencies and Repairs. These sections outline the results of the sites’ facilities inspections, for the same period, using the state’s Facilities Inspection Tool form. This inspection determines the school facility’s condition status using ratings of exemplary, good, fair or poor condition. Recommendations for Recovery 1. Information on the status of school facilities improvement projects and the conditions of school facilities on the district website should be updated regularly in its IUSD Progress Report and Construction Projects reporting sections. Facilities Management 477 2. The district should ensure school website links titled Construction Projects are working and the content is accessible to provide information to the public regarding the status of projects at each school site. 3. The district should continue to distribute its e-newsletter, as well as discuss facilities projects on its social media accounts to help keep the local community informed. 4. The district should continue to regularly make public presentations on the status of its facilities and maintenance projects at district board meetings. 5. The district should provide more detailed information in the minutes of the CBOC meetings regarding what information is presented to the committee, and any comments, questions or concerns expressed by committee members so that the public at large can better understand what is discussed in the meetings. 6. The district should continue to publish its SARC forms, which include facility conditions, on its website each year. Standard Fully Implemented July 2013 Rating: 6 July 2014 Rating: 6 July 2015 Rating: 7 July 2016 Rating: 6 July 2017 Rating: 7 July 2018 Rating: 7 July 2019 Rating: 7 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 8 July 2022 Rating: 8 July 2023 Rating: 8 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 478 Facilities Management 10.1 Charter Schools Legal Standard The LEA meets the audit and reporting requirements of Proposition 39 as it relates to charter schools. (EC 47614; CCR Title 5, Sections 11969.1-11969.10) Findings 1. BP 7160 supports the access of charter school students to safe and adequate facilities and was last updated August 20, 2014. Under this board policy, the district is required to make facilities available to eligible charter schools in accordance with law. These facilities are to be contiguous, furnished, equipped, and sufficient to accommodate students in conditions reasonably equivalent to those of students attending other district schools. 2. The previous county administrator, along with an administrative team, indicated they visited each charter school authorized by the district twice per year to review operations and finances. The district provided evidence of visits to charter schools during the current review period. The district no longer uses the services of an outside consultant to monitor and audit the charter schools operating in the district. The new chief business official indicated the district is monitoring and auditing the fiscal activities of charter schools authorized by the district. 3. According to district staff, no new charter school applications were received during this review period; however, at the June 22, 2022, board meeting, a facility use agreement was approved for Green Dot Public Schools to operate the already established Animo City of Champions High School at the old Warren Lane school site. 4. The county administrator indicated that in 2020 Lennox Unified School District, a neighboring school district, approved the Century Community Charter School, a charter middle school that is within the boundary of Inglewood Unified. He also indicated the matter is currently under litigation. Recommendations for Recovery 1. The district should continue to evaluate and update BP and AR 7160 to ensure they reflect the latest legal and other requirements of both the state and the district. 2. The district should continue to maintain compliance with BP and AR 7160 supporting charter school facility needs requests. 3. The district should continue to provide continuous educational and fiscal oversight of the charter schools approved by the district. 4. The district should continue to consider facilities use requests from charter schools as they are submitted. Facilities Management 479 Standard Fully Implemented July 2013 Rating: 2 July 2014 Rating: 8 July 2015 Rating: 8 July 2016 Rating: 9 July 2017 Rating: 10 July 2018 Rating: 10 July 2019 Rating: 10 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 10 July 2022 Rating: 10 July 2023 Rating: 10 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 480 Facilities Management 13.2 Maintenance and Operations Fiscal Controls Professional Standard The Maintenance and Operations departments follow standard LEA purchasing protocols. Open purchase orders may be used if controlled by limiting the employees authorized to make the pur- chase and the amount. Findings 1. In previous reviews the district had developed and provided a Purchasing/Warehouse Procedures/Guidelines manual that provided guidelines, policies and procedures governing the Purchasing/Warehouse Department. The manual provided by the district contained some purchasing best practices and interpretations of laws and rules and regulations for school districts. The manual was designed to assist schools, office managers, departments, and noninstructional personnel to receive the highest quality of goods and services. As of the date of FCMAT’s fieldwork, this manual had not been provided to the facilities team. However, the district has a comprehensive purchasing webpage titled Procurement Services. This webpage offers a workflow process diagram, instructions for submitting purchase orders, and opportunities to request training. Additionally, the finance team had been provided a draft Purchasing Department SOP 2022-2023. 2. According to the job description, the senior storekeeper is responsible for purchasing all the supplies held in the warehouse. 3. Documentation provided indicates that there is a reasonable number of open purchase orders. Open purchase orders are to identify those who are authorized to purchase supplies or noncapitalized equipment on behalf of the district; however, as with prior review findings, they do not consistently contain information identifying authorized users. 4. Interviews with the operations staff revealed that the district has recently changed financial software. The district previously used PeopleSoft and now uses BEST. Although the BEST system provides for electronic requisitions, staff indicated that a “paper” system for requisitions of materials and supplies for school sites was still being used. The paper system equates to email requests from sites, which are printed, and deliveries are signed for by the receiver. Recommendations for Recovery 1. The district should ensure a purchasing manual that provides purchasing and inventory management policies, guidelines and procedures is available to all staff and is annually updated with the latest guidance including the maximum bid threshold as determined by the CDE. Effective January 1, 2023, the bid threshold was updated to $109,300. Facilities Management 481 2. All district purchasing procedures should be communicated to the appropriate staff members. With hiring of new personnel, the district will need to ensure these employees are trained to follow department and district policy and procedures. 3. The district should develop a schedule to routinely review and update the purchasing procedures manual at a frequency that supports the district’s processes and coincides with the district’s purchasing authority renewal schedule. This schedule should become part of the manual, and assigned staff should update and publish this document accordingly. The date of the update should also be displayed on the manual. 4. The district should continue to maintain a justifiable number of open purchase orders in use by the Maintenance, Operations and Transportation Department. Open purchase orders should always indicate who is authorized to purchase supplies or noncapitalized equipment on behalf of the district. 5. The district should provide site and department administrators and managers with training on purchasing best practices and district policy. Standard Partially Implemented July 2013 Rating: 3 July 2014 Rating: 3 July 2015 Rating: 3 July 2016 Rating: 3 July 2017 Rating: 3 July 2018 Rating: 4 July 2019 Rating: 4 July 2020 Rating: Omitted per SB 98, Section 102 due to COVID-19 pandemic July 2021 Rating: 3 July 2022 Rating: 3 July 2023 Rating: 3 0 1 2 3 4 5 6 7 8 9 10 Implementation Scale: Not Fully 482 Facilities Management Facilities Management 483 484 Facilities Management Table of Facilities Management Ratings Facilities Management 485 486 Facilities Management July July July July July July July July July July July Facilities Management Standards 2013 2014 2015 2016 2017 2018 2019 2020 Rat- 2021 2022 2023 Rating Rating Rating Rating Rating Rating Rating ing Rating Rating Rating LEGAL STANDARD – SCHOOL SAFETY The LEA has adopted policies and regulations and implemented written plans describing procedures to be followed Omitted in case of emergency, in accordance per SB 98, with required regulations. All school Section 1.1 2 2 3 3 5 7 7 7 7 7 administrators are conversant with these 102 due to policies and procedures. (EC 32001- COVID-19 32290, 35295-35297, 46390-46392, pandemic. 49505; GC 3100, 8607; CCR Title 5, Section 550, Section 560; Title 8, Section 3220; Title 19, Section 2400) LEGAL STANDARD – SCHOOL SAFETY Omitted The LEA has developed a comprehensive per SB 98, safety plan that includes adequate Section 1.3 3 3 3 3 4 6 5 6 6 5 measures to protect people and property. 102 due to (EC 32020, 32211, 32228-32228.5, COVID-19 35294.10-35294.15) pandemic. Omitted LEGAL STANDARD – SCHOOL SAFETY per SB 98, School premises are sanitary, neat, Section 1.8 clean and free from conditions that would 2 3 3 2 4 6 5 5 6 6 102 due to create a fire or life hazard. (CCR Title 5, COVID-19 Section 630) pandemic. Omitted LEGAL STANDARD – SCHOOL SAFETY per SB 98, The LEA complies with Injury and Illness Section 1.9 1 1 3 2 5 6 5 5 7 6 Prevention Program requirements. (CCR 102 due to Title 8, Section 3203) COVID-19 pandemic. Omitted LEGAL STANDARD – SCHOOL SAFETY per SB 98, The LEA maintains updated material Section 1.15 safety data sheets for all required 1 2 2 2 3 5 6 5 6 5 102 due to products. (LC 6360-6363; CCR Title 8, COVID-19 Section 5194) pandemic. PROFESSIONAL STANDARD – SCHOOL SAFETY Omitted The LEA has a documented process per SB 98, for issuing and retrieving master and Section 1.16 3 3 4 4 5 6 6 6 6 7 submaster keys. All administrators follow 102 due to a standard organizationwide process for COVID-19 issuing keys to and retrieving keys from pandemic. employees. PROFESSIONAL STANDARD – SCHOOL Omitted SAFETY per SB 98, Outside lighting is properly placed and Section 1.18 is monitored periodically to ensure that it 5 5 6 5 5 5 5 5 7 7 102 due to functions and is adequate to ensure safety COVID-19 during evening activities for students, staff pandemic. and the public. PROFESSIONAL STANDARD – SCHOOL SAFETY Omitted The LEA maintains a comprehensive per SB 98, employee safety program. Employees Section 1.20 1 1 2 2 5 6 6 6 6 5 are made aware of the LEA’s safety 102 due to program, and the LEA provides in-service COVID-19 training to employees on the program’s pandemic. requirements. Facilities Management 487 July July July July July July July July July July July Facilities Management Standards 2013 2014 2015 2016 2017 2018 2019 2020 Rat- 2021 2022 2023 Rating Rating Rating Rating Rating Rating Rating ing Rating Rating Rating LEGAL STANDARD – FACILITY Omitted PLANNING per SB 98, The LEA seeks and obtains waivers from Section 2.2 0 0 N/A N/A N/A N/A N/A N/A N/A N/A the State Allocation Board for continued 102 due to use of any nonconforming facilities. (EC COVID-19 17284-17284.5) pandemic. LEGAL STANDARD – FACILITY Omitted PLANNING per SB 98, The LEA has established and uses a Section 2.3 1 1 4 6 6 7 7 6 7 6 selection process to choose licensed 102 due to architectural/engineering services. (GC COVID-19 4525-4526) pandemic. PROFESSIONAL STANDARD – Omitted FACILITY PLANNING per SB 98, The LEA has a long-range school facilities Section 2.6 3 4 6 6 6 6 7 2 3 5 master plan that has been updated in the 102 due to last two years and includes an annual COVID-19 capital planning budget. pandemic. Omitted per SB 98, PROFESSIONAL STANDARD – Section 2.8 FACILITY PLANNING 0 0 2 3 3 3 3 0 0 3 102 due to The LEA has a facility planning committee. COVID-19 pandemic. Omitted LEGAL STANDARD – FACILITIES per SB 98, IMPROVEMENT AND MODERNIZATION Section 3.1 2 3 5 6 5 5 6 5 6 6 The LEA maintains a plan for maintaining 102 due to and modernizing its facilities. (EC 17366) COVID-19 pandemic. Omitted LEGAL STANDARD – FACILITIES per SB 98, IMPROVEMENT AND MODERNIZATION Section 3.3 2 2 3 3 3 3 3 3 4 4 All relocatable buildings in use meet 102 due to statutory requirements. (EC 17292) COVID-19 pandemic. PROFESSIONAL STANDARD – Omitted FACILITIES IMPROVEMENT AND per SB 98, MODERNIZATION Section 3.9 The LEA manages and annually reviews 0 0 N/A N/A N/A N/A N/A N/A N/A N/A 102 due to its five-year deferred maintenance plan COVID-19 and verifies that expenditures made pandemic. during the year are included in the plan. PROFESSIONAL STANDARD – Omitted FACILITIES IMPROVEMENT AND per SB 98, MODERNIZATION Section 3.10 The LEA’s staff are knowledgeable about 2 0 2 4 3 3 3 3 5 6 102 due to procedures in the Office of Public School COVID-19 Construction (OPSC) and the Division of pandemic. the State Architect (DSA). Omitted PROFESSIONAL STANDARD – per SB 98, CONSTRUCTION OF PROJECTS Section 4.1 The LEA maintains a staffing structure 1 1 1 5 4 4 4 4 5 6 102 due to that is adequate to ensure the effective COVID-19 management of its construction projects. pandemic. Omitted PROFESSIONAL STANDARD – per SB 98, CONSTRUCTION OF PROJECTS Section 4.2 8 8 9 9 9 9 9 9 9 9 The LEA maintains appropriate project 102 due to records and drawings. COVID-19 pandemic. 488 Facilities Management July July July July July July July July July July July Facilities Management Standards 2013 2014 2015 2016 2017 2018 2019 2020 Rat- 2021 2022 2023 Rating Rating Rating Rating Rating Rating Rating ing Rating Rating Rating LEGAL STANDARD – FACILITIES MAINTENANCE AND OPERATIONS The LEA is in compliance with Omitted requirement of the Williams case per SB 98, settlement. The governing board provides Section 6.1 clean and operable flush toilets for 3 3 5 3 4 6 5 5 6 4 102 due to students’ use; toilet facilities are adequate COVID-19 and maintained. All buildings and grounds pandemic. are maintained. (EC 17576, 17592.70- 17592.73, 35186; CCR Title 5, Section 631, Section 4683, Section 14030) Omitted LEGAL STANDARD – FACILITIES per SB 98, MAINTENANCE AND OPERATIONS Section 6.2 The LEA has established the required 2 2 6 6 6 6 6 6 6 6 102 due to account for ongoing and major COVID-19 maintenance. (EC 17014, 17070.75) pandemic. PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND Omitted OPERATIONS per SB 98, The LEA uses and maintains a system to Section 6.3 track utility costs and consumption and 0 0 1 1 2 2 2 1 1 1 102 due to to report on the success of its energy COVID-19 program in reducing the cost of utilities. pandemic. An energy analysis has been completed for each site. PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND OPERATIONS To safeguard items from loss, the LEA Omitted keeps adequate maintenance records and per SB 98, reports, including a complete inventory of Section 6.4 supplies, materials, tools and equipment. 2 2 2 2 4 6 5 5 5 4 102 due to All employees who are required to COVID-19 perform custodial, maintenance or pandemic. grounds work on LEA sites are provided with adequate supplies, equipment and training to perform maintenance tasks in a timely and professional manner. PROFESSIONAL STANDARD – Omitted FACILITIES MAINTENANCE AND per SB 98, OPERATIONS Section 6.5 Procedures are in place for evaluating 2 2 3 3 4 6 4 3 3 2 102 due to the quality of the work performed by COVID-19 maintenance and operations staff, and pandemic. evaluations are completed regularly. PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND Omitted OPERATIONS per SB 98, The LEA has identified major areas of Section 6.6 custodial and maintenance responsibility 2 2 4 4 5 4 4 4 4 4 102 due to and specific jobs to be performed. COVID-19 Written job descriptions for custodial and pandemic. maintenance positions delineate the major areas of responsibility for each position. PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND Omitted OPERATIONS per SB 98, The LEA has an effective written Section 6.7 0 0 1 1 1 2 2 2 2 2 preventive maintenance plan that 102 due to is scheduled and followed by the COVID-19 maintenance staff and that includes pandemic. verification of work completed. Facilities Management 489 July July July July July July July July July July July Facilities Management Standards 2013 2014 2015 2016 2017 2018 2019 2020 Rat- 2021 2022 2023 Rating Rating Rating Rating Rating Rating Rating ing Rating Rating Rating PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND OPERATIONS Omitted The LEA has planned and implemented per SB 98, a maintenance program that includes an Section 6.8 inventory of all facilities and equipment 0 0 0 0 2 2 2 2 2 0 102 due to that will require maintenance and COVID-19 replacement. Data should include pandemic. estimated life expectancies, replacement timelines and the financial resources needed to maintain the facilities. PROFESSIONAL STANDARD – FACILITIES MAINTENANCE AND OPERATIONS Omitted The LEA has a documented process for per SB 98, prioritizing and assigning routine repair Section 6.9 2 2 4 4 5 5 4 4 4 4 work orders. The LEA has a work order 102 due to system that tracks all maintenance COVID-19 requests, the employee assigned, dates pandemic. of completion, labor hours and the cost of materials. Omitted LEGAL STANDARD – INSTRUCTIONAL per SB 98, PROGRAM ISSUES Section 7.2 The LEA has developed and maintains a 3 3 3 3 3 3 3 3 3 3 102 due to plan to ensure the equality and equity of COVID-19 all of its school site facilities. (EC 35293) pandemic. Omitted PROFESSIONAL STANDARD – per SB 98, INSTRUCTIONAL PROGRAM ISSUES. Section 7.4 The LEA’s grounds are appropriately 3 3 5 4 4 5 4 3 4 4 102 due to landscaped and maintained to enhance COVID-19 an educational environment. pandemic. Omitted PROFESSIONAL STANDARD – per SB 98, COMMUNITY USE OF FACILITIES Section 8.2 7 8 8 8 9 9 10 10 9 9 The LEA has a plan to promote 102 due to community involvement in schools. COVID-19 pandemic. PROFESSIONAL STANDARD – Omitted COMMUNICATION per SB 98, The LEA fully apprises students, staff and Section 9.1 community of the condition of its facilities 6 6 7 6 7 7 7 8 8 8 102 due to and its plans to remedy any substandard COVID-19 conditions. The LEA provides access to its pandemic. facilities staff, standards and plans. LEGAL STANDARD – CHARTER Omitted SCHOOLS per SB 98, The LEA meets the audit and reporting Section 10.1 2 8 8 9 10 10 10 10 10 10 requirements of Proposition 39 as it 102 due to relates to charter schools. (EC 47614; COVID-19 CCR Title 5, Sections 11969.1-11969.10) pandemic. PROFESSIONAL STANDARD – MAINTENANCE AND OPERATIONS Omitted FISCAL CONTROLS per SB 98, The Maintenance and Operations Section 13.2 departments follow standard LEA 3 3 3 3 3 4 4 3 3 3 102 due to purchasing protocols. Open purchase COVID-19 orders may be used if controlled by pandemic. limiting the employees authorized to make the purchase and the amount. Collective Average Rating 2.24 2.59 3.81 3.94 4.65 5.29 5.13 – 4.71 5.16 5.06 490 Facilities Management Glossary of Acronyms Glossary of Acronyms 491 492 Glossary of Acronyms ACRONYM DEFINITION AB Assembly Bill ADA Average Daily Attendance ALT Accelerated Learning Teacher AON AON Risk Solutions AP Advanced Placement AR Administrative Regulation ASB Associated Student Body ASCIP Alliance of Schools for Cooperative Insurance Programs BB Board Bylaw BEST Business Enhancement System Transformation BP Board Policy CAASPP California Assessment of Student Performance and Progress CALPADS California Longitudinal Pupil Achievement Data System CalPro California Professional Employees CAO Chief Academic Officer CASBO California Association of School Business Officials CASH Coalition for Adequate School Housing CBEDS California Basic Educational Data System CBO Chief Business Official CBOC Citizens’ Bond Oversight Committee CCEE California Collaborative for Educational Excellence CCR California Code of Regulations CCSS Common Core State Standards CDE California Department of Education CFR Code of Federal Regulations CODESP Cooperative Organization for the Development of Employee Selection Procedures CoI Cycle of Inquiry COO Chief Operating Officer CPSEL California Professional Standards for Education Leaders CSAM California School Accounting Manual CSBA California School Boards Association CSIS California School Information Services CSTP California Standards for the Teaching Profession CSU California State University CTE Career Technical Education CTF California Teleconnect Fund CUPCCAA California Uniform Public Construction Cost Accounting Act Dashboard California School Dashboard DBA Database Administrator DIBELS Dynamic Indicators of Basic Early Literacy Skills DIR Department of Industrial Relations DITAC District Information Technology Advisory Committee DOK Depth of Knowledge Glossary of Acronyms 493 DSA Division of the State Architect EC Education Code ECF Emergency Connectivity Fund EDD Employment Development Department EdTech Educational Technology EEOC Equal Employment Opportunity Commission ELA English/Language Arts ELD English Language Development ELL English Language Learner ELPAC English Language Proficiency Assessments for California EMS Energy Management System ESEA Elementary and Secondary Education Act ESSA Every Student Succeeds Act ESSER Elementary and Secondary School Emergency Relief FADA Funded Three-Year Average Daily Attendance FCMAT Fiscal Crisis and Management Assistance Team FIT Facilities Inspection Tool FMLA Family Medical Leave Act FMP Facilities Master Plan FPM Federal Program Monitoring FSP Fiscal Stabilization Plan FTE Full-Time Equivalents GASB Governmental Accounting Standards Board GATE Gifted and Talented Education Gbps Gigabytes Per Second GC Government Code GO General Obligation HCM Human Capital Management HR Human Resources HRS Human Resource System HVAC Heating, Ventilation and Air Conditioning IAB Interim Assessment Block I-Bank California Infrastructure and Economic Development Bank IBB Interest-based Bargaining ICHS Inglewood Continuation High School IDEA Individuals with Disabilities Education Act IEP Individualized Education Program IIPP Injury and Illness Prevention Program IMA Inglewood Management Association ISP Internet Service Provider IT Information Technology ITA Inglewood Teachers Association ITC Instructional Technology Committee IUSD Inglewood Unified School District JPA Joint Powers Authority 494 Glossary of Acronyms Keenan Keenan & Associates LACOE Los Angeles County Office of Education LAWA Los Angeles World Airports LCAP Local Control and Accountability Plan LCFF Local Control Funding Formula LCI Licensed Children’s Institution LEA Local Educational Agency LRE Least Restrictive Environment MOT Maintenance, Operations and Transportation MOU Memorandum of Understanding MTSS Multi-Tiered System of Supports MYFP Multiyear Financial Projection NCLB No Child Left Behind NPA Nonpublic Agency NPS Nonpublic School NSLP National School Lunch Program OMB Office of Management and Budget OPEB Other Post-Employment Benefits OPSC Office of Public School Construction OPUS Online Public Update for Schools PADC Principal Apportionment and Data Collection PAF Personnel Action Form PBIS Positive Behavior Interventions and Supports PCC Public Contract Code PIP Performance Improvement Plan PLC Professional Learning Community PPM Policy and Procedures Manual RAD Reports and Data RFP Request for Proposal RFQ Request for Statement of Qualifications RRMA Routine Restricted Maintenance Account RSTS Regional School Transportation Services RtI Response to Intervention SAB State Allocation Board SACS Standardized Account Code Structure SARB Student Attendance Review Board SARC School Accountability Report Card SART Student Attendance Review Team SAS Statements on Auditing Standards SB Senate Bill SBE State Board of Education SCROC Southern California Regional Occupational Center SD/OI Severely Disabled/Orthopedically Impaired SDS Safety Data Sheet SEIS Special Education Information System Glossary of Acronyms 495 SELPA Special Education Local Plan Area SIR Systemic Instructional Review SIS Student Information System SOP Standard Operating Procedure SPI Superintendent of Public Instruction SPSA School Plan for Student Achievement SSC School Site Council SSN Social Security Number SST Student Study Team SWDs Students with Disabilities TBD To Be Determined TK Transitional Kindergarten TOSA Teacher on Special Assignment UC University of California UCP Uniform Complaint Procedures UPC Unduplicated Pupil Count USAC Universal Servicer Administrative Company USC United States Code UTK Universal Transitional Kindergarten VARs Value-Added Resellers 496 Glossary of Acronyms