FCMAT
Monterey County Office of Education Report
county office of education annual oversight evaluation
Read the report at Monterey County Office of Education ↗
Annual Review
March 6, 2023
Monterey County
Office of Education
Michael H. Fine
Chief Executive Officer
March 6, 2023
Deneen Guss, Ed.D., Superintendent
Monterey County Office of Education
901 Blanco Circle
Salinas, CA 93901
Dear Superintendent Guss:
In February 2020, the Monterey County Office of Education and the Fiscal Crisis and Management
Assistance Team (FCMAT) entered into an agreement for FCMAT to perform the following:
Prepare an initial analysis of the county office fiscal oversight provided to the South Monterey
County Joint Union High School District using FCMAT’s County Office Evaluation Tool, and
make recommendations for improvement, if any.
The February 2020 study agreement also covers annual follow-up evaluations.
This report contains the FCMAT study team’s findings and recommendations from the second annual eval-
uation of the county superintendent’s oversight of the South Monterey County Joint Union High School
District.
FCMAT appreciates the opportunity to serve the Monterey County Office of Education and extends thanks
to its staff for their cooperation and assistance during this review.
Sincerely,
Michael H. Fine
Chief Executive Officer
Michael H. Fine • Chief Executive Officer
1300 17th Street – City Centre, Bakersfield, CA 93301-4533 • Tel. 661-636-4611 • Fax 661-636-4647
www.fcmat.org
Table of Contents
Table of Contents
Introduction .......................................................................................................1
Background ............................................................................................................................1
County Office Evaluation Guidelines ................................................................................1
Study Team ............................................................................................................................2
County Office Evaluation Tool .....................................................................3
Summary ...........................................................................................................4
Findings ............................................................................................................5
General Conclusions and Recommendations ........................................9
Appendices .....................................................................................................10
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AB 1840 Annual Evaluation
Introduction
Background
In September 2018, Governor Brown signed Assembly Bill (AB) 1840, making a significant change in how
insolvent school districts are administered after they receive a state emergency appropriation. As part of
that legislation, codified in Education Code Section 41326(l), the Fiscal Crisis and Management Assistance
Team (FCMAT) was given the responsibility of reviewing the fiscal oversight performed by the county super-
intendent of schools for any district receiving an emergency apportionment. FCMAT is required to report
its findings to the Legislature and provide a copy of that report to the Department of Finance, the superin-
tendent of public instruction (SPI), and the president of the State Board of Education (SBE). This report is
required to include findings regarding fiscal oversight actions that were or were not taken and may include
recommendations for an appropriate legislative response to improve fiscal oversight of school districts.
In the years following the initial FCMAT report of fiscal oversight performed by the county superintendent of
schools, FCMAT will complete annual reviews until the district exits receivership. These reviews will assess
the effectiveness of the county superintendent of schools’ oversight and its involvement with the district,
including during the period that led to the district’s declaration of insolvency.
On July 23, 2009, Senate Bill (SB) 130 (Denham, co-author Assembly Member Caballero) was signed into
law, authorizing the appointment of a state administrator and providing a $13 million emergency state loan
or line of credit to the King City Joint Union High School District (later renamed the South Monterey County
Joint Union High School District). This insolvency occurred after several years of financial struggles that
were punctuated by significant issues related primarily to collective bargaining. At the core of the district’s
struggles was a difference in interpretation of a signed and approved collective bargaining agreement
that was negotiated in 2007. After a series of attempts to solve the dispute, the case was forwarded to
the Public Employee Relations Board (PERB) to adjudicate. As a result of PERB’s final decision, the district
found itself in severe financial distress, which eventually led to fiscal insolvency. Had the PERB decision not
reversed the district’s position on the collective bargaining issue, the district might have remained solvent,
although the county office had communicated fiscal issues and concerns related to the cost of total com-
pensation for all staff prior to the declaration of insolvency.
County Office Evaluation Guidelines
FCMAT entered into a study agreement with the Monterey County Office of Education on February 15,
2020 for both the initial and annual evaluations required by Education Code Section 41326(l). A study team
visited the county office on March 9, 2020 for the initial evaluation, on October 20, 2021 for the first annual
evaluation, and on January 19, 2023 for the current evaluation, to conduct interviews, collect data and
review documents. Following fieldwork, the study team continued to review and analyze documents. This
report is the result of those activities and actions related to the annual evaluation.
FCMAT’s reports focus on systems and processes that may need improvement. Those that may be func-
tioning well are generally not commented on in FCMAT’s reports. In writing its reports, FCMAT uses the
Associated Press Stylebook, a comprehensive guide to usage and accepted style that emphasizes con-
ciseness and clarity. In addition, this guide emphasizes plain language, discourages the use of jargon, and
capitalizes relatively few terms.
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Study Team
The team was composed of the following members:
Michelle Giacomini Nicolas Schweizer
FCMAT Deputy Executive Officer FCMAT Consultant
Misty Key Sheldon Smith
FCMAT Consultant FCMAT Consultant
John Lotze
FCMAT Technical Writer
Each team member reviewed the draft report to confirm accuracy and achieve consensus on the analysis.
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County Office Evaluation Tool
The Fiscal Crisis and Management Assistance Team (FCMAT) has developed the County Office Evaluation
Tool (COET) for the initial and annual evaluations to help assess the effectiveness of a county super-
intendent of schools’ fiscal oversight and support of school districts that have received an emergency
apportionment.
The annual COET includes 12 questions and is intended to satisfy the requirements of Education Code
Section 41326(l) for review and assessment of the county superintendent of schools’ fiscal oversight and
support related to a school district’s recovery. The tool is focused on the status of the district’s recovery,
the continuing implementation of the long-range recovery plan (LRRP), the role of the administrator or
trustee, the multiyear financial projection, and how the county superintendent is addressing elements that
received an answer of “No” in the initial evaluation. FCMAT used the annual COET during interviews with
multiple staff from both the district and the county office, and the trustee.
The COET identifies the key review elements performed by the county superintendent of schools in its
fiscal oversight and support of the district and their ability to communicate effectively with the trustee,
district staff and board. FCMAT also gathered information through an initial document request before the
on-site interviews. The FCMAT team’s conclusions are compiled in the report as a narrative, with recom-
mendations noted as appropriate. In addition, the team addressed questions related to the overall imple-
mentation of Education Code Section 41326(l) and made recommendations to support that process, includ-
ing a restatement of the specific roles and responsibilities of the trustee.
The county superintendent of schools’ objective, supported by the trustee and other components of a
recovery team (FCMAT, the California Department of Education and SBE), is to facilitate the full recov-
ery and address the major elements of the LRRP of the South Monterey County Joint Union High School
District so that it can govern independently, maintain solvency, and effectively support the education of all
students.
County Office Name: Monterey County Office of Education
Date of Fieldwork: January 19, 2023
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Summary
The Monterey County Superintendent of Schools provides fiscal oversight to all the county’s school dis-
tricts as a result of the original AB 1200 legislation, which was signed into law in 1991 and is expressed in
Article 2, Chapter 6 of Part 24 of the California Education Code, starting with Section 42120 and/or Section
1240(b).
During the initial 41326(l) evaluation, FCMAT assessed the county superintendent of schools’ involvement
with the district during its normal oversight responsibilities and specifically during the period that led to
the district’s declaration of insolvency and beyond, up to and including the date of the evaluation. To do
so, FCMAT reviewed documents prepared by county office staff and asked a series of questions relating to
the time leading up to the insolvency in addition to reviewing oversight practices employed by the county
office.
The annual evaluation focuses on the status of the district’s recovery, whether the district has made prog-
ress since the last review, and how effectively the county superintendent of schools supports the district’s
staff, board, and trustee in that process. In addition, the annual review evaluates any area from the initial
review listed as a “No” on the tool and determines if those issues continue to be addressed.
The team’s findings indicate the county superintendent of schools is effective in supporting the full recov-
ery of the district within the guidelines in the California Education Code and the findings and recommenda-
tions in the LRRP. Since FCMAT’s last visit, the county superintendent of schools has further increased its
engagement with the district, and the Comprehensive Review and Recovery Plan has become the guiding
document and measurement tool for the district’s recovery. In addition to its normal oversight responsibil-
ities and duty to oversee the district’s implementation of the LRRP, the county superintendent of schools
has assigned a lead county office staff member to each of their district counterparts for additional support,
organized around the five comprehensive plan areas. The county superintendent also clarified the county
trustee’s role and interaction with the school district so that the trustee can interface with district staff and
the board on all aspects of district operational improvement. There is significant communication between
the district and the county superintendent of schools, which provides direction to the district while moni-
toring its progress. The county superintendent is requiring the district to perform a self-evaluation, and the
county superintendent’s office has developed a spreadsheet for each area of the comprehensive review
for the district to complete, itemizing the actions district staff have taken and providing evidence to demon-
strate progress. The self-evaluation and spreadsheet will become a focal point in the meetings between the
county superintendent and the district as the district begins to use the tool more effectively.
FCMAT found that communication among the county superintendent of schools, county office staff and
county trustee in the current model of oversight was timely and consistent with a focus on district recovery.
Concerns remain about providing programs and services for students at the expense of a conservative
budget mindset. The high turnover of the district superintendent position has created an unstable environ-
ment, causing a lack of progress on increasing student academic achievement and creating a leadership
void, resulting in inadequate support to meet the needs of all students. Because the indicators of student
performance continue to demonstrate a need for improvement, the county superintendent of schools
should ensure that the district focuses on increasing services to students while maintaining a balanced
budget, and that it invests in multiple leadership positions to lead its instructional programs and increase
student achievement.
The following section of this report focuses on FCMAT’s implementation of the annual COET, including
general findings and, in some cases, recommendations for improvement. All the areas assessed are listed
below with an associated narrative. If a deficiency in the area is material, it is noted in the narrative.
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Findings
1. Was the Long-Range Recovery Plan (LRRP) developed by the administrator within the statutory
timelines? Alternatively, has the county office of education (COE) adopted the FCMAT compre-
hensive review in lieu of the LRRP? Have the plans been consistently updated by the trustee and/
or COE?
The district uses the FCMAT Comprehensive Review in lieu of an LRRP.
The county superintendent of schools indicated that a process similar to Western Association of
Schools and Colleges (WASC) accreditation is being used that includes district self-evaluations and
requires the district to demonstrate evidence of progress on the comprehensive review standards.
Although the district has plans to address deficiencies identified in the comprehensive review and
has developed a District Recovery Plan to reflect their action, it has failed to keep the plan updated.
This is in part due to turnover in the district superintendent position over the last year. In addition,
the district’s governing board has not made implementation of the plans a priority. Although the
board is given updates at board meetings through the district superintendent's Recovery Plan
Update, more attention and accountability is needed.
The trustee should report the district’s progress toward implementing the outstanding findings and
recommendations in the LRRP to the county superintendent and other interested parties at least
annually. The District Recovery Plan could be used to support the report if the plan is maintained.
FCMAT could then use the trustee’s annual report in subsequent annual evaluations to help assess
progress related to the district’s recovery.
2. What role has the COE played in supporting the district with the Long-Range Recovery Plan?
The county superintendent of schools’ office has continued its monthly meetings with district
staff and the trustee to track progress in addressing deficiencies identified in the comprehensive
review and to support the district. Since FCMAT’s last visit, the county superintendent of schools
has implemented a number of strategies that engender engagement and communication with the
school district. Primary to the increased engagement is the county superintendent assigning county
superintendent personnel to the district. The county superintendent assigned a lead county office
staff member to each of their district counterparts, organized around the five comprehensive plan
areas, with a directive to meet at least monthly with them. The county superintendent also clarified
the county trustee’s role and interaction with the school district so the trustee can communicate
with district staff and the board on all aspects of operational improvement, not exclusively finance.
In addition, the district superintendent now has a standing Recovery Plan Update item on each
board of trustees meeting agenda.
The area of greatest need for the district is to increase student achievement. Despite the county
superintendent’s support, the lack of a permanent district superintendent has hampered the prog-
ress being made in this area.
These initiatives by the county superintendent have increased interaction with the district, helped
district recovery, and increased trust among the parties. The interviews revealed that more frequent
and systematic interaction with the district (including instructional) helps district staff focus on
recovery throughout the year rather than only when an oversight visit is impending.
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3. What process has the COE used to monitor the progress of implementing the LRRP or the FCMAT
Comprehensive Review for the district?
There is regular, ongoing communication between the district and the county superintendent of
schools that provides direction to the district while also monitoring its progress, including monthly
meetings between the county superintendent of schools and key staff, as well as meetings between
the trustee and the district superintendent. The county superintendent is requiring the district to
perform a self-evaluation, and the spreadsheets that the county superintendent’s office has devel-
oped for each area of the comprehensive review are designed for the district to itemize evidence
and the actions that district staff have taken to address the deficiencies to demonstrate progress.
This information will become more of a focus in the meetings as the district begins to use the
self-evaluation more effectively. The county superintendent of schools is creating and implementing
processes that support the use of the most recent comprehensive review as the measuring tool and
guidance mechanism. The county superintendent has set up systems and processes with checklists
and files to maintain progress checks and documentation to follow the district and ensure detailed
monitoring is occurring and progress is being made toward financial recovery.
4. What role has the trustee played in maintaining the financial recovery plan in cooperation with
the COE?
Since FCMAT’s last visit, the trustee has greater access to all operational areas of the district, not
just finance, so that he can assess the needs in all five operational areas of the comprehensive
review, monitor all district operations, and support the continuing focus on long-term recovery.
The trustee has been included in all governing board closed sessions and can provide input and
support through the discussions and meetings he attends. The district staff and governing board
understand the trustee's role and are supportive of his involvement in all district operations and
as the point of contact with the county superintendent of schools. The trustee did not use stay or
rescind authority in the last year. The comprehensive review is now on the monthly board agendas.
The trustee plans to use FCMAT’s Fiscal Health Risk Analysis (FHRA) tool to guide his work with the
district. Using the FHRA will provide actionable areas to monitor and report to the district’s busi-
ness services department as well as to the county superintendent of schools to focus on in their
daily oversight of the district.
5. What is the status of the district’s budget regarding deficit spending, fund balance, and reserve
for economic uncertainties?
The district’s budget is sound. At 2022-23 first interim, in addition to fund designations for capital
outlay and other district priorities, it includes budget surpluses, a large unrestricted fund balance
of $10,673,048, and a reserve for economic uncertainties of 10.62% of general fund expenditures,
which is well in excess of the minimum requirement of 3%. The district has a positive financial
certification. Because of its role related to fiscal oversight, the county office monitors the levels of
fund balance to ensure that services to students are fully supported and that the district is meet-
ing its goals, objectives and actions in its Local Control and Accountability Plan (LCAP) to support
improved student outcomes and achievement.
However, the district is not investing as heavily in programs and services for students as it could
to increase academic achievement. The lack of stable leadership has hindered progress on the
district’s student outcomes. It is recommended the district invest in several high-level administrator
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positions to lead and increase the focus on academic achievement, with the goal of stable leader-
ship to make progress on increasing outcomes for students.
6. What process does the COE use to assess cash flow?
The county superintendent’s staff monitors cash balances daily, and reviews district cash flow
projections and balances cash monthly for all districts. Given the district's significant fund balance,
cash flow is not an issue.
The Monterey County treasurer collects school dollars using a process in which schools can be
negative in cash if the fund supporting those dollars is in a positive position.
7. Has the COE fulfilled all of the statutory requirements for fiscal oversight in accordance with all
applicable sections of the Education Code?
The county office continues to fulfill all the statutory requirements for fiscal oversight in accordance
with the applicable Education Code sections. In performing standard AB 1200/AB 2756 oversight
functions, the county superintendent has demonstrated that its process and procedures are at or
above industry standard among the 57 other county offices of education.
8. Has the COE performed timely evaluations of the trustee?
The trustee was evaluated in May 2022. The growth goals set by the county superintendent of
schools are specific: use the FHRA and create a tool to monitor district recovery plan progress as
well as be more involved in staff training.
The tool being used is a standard evaluation tool and easy to follow. Including the FHRA is a good
example of the concept that work that is measured gets accomplished. The FHRA provides direc-
tion to the trustee to examine functions and processes that if not followed could result in risk to the
district’s fiscal health.
9. Is the trustee present at board meetings and closed sessions? Has the trustee used stay or re-
scind authority and, if so, regarding what issue?
The trustee is present at all board meetings and closed sessions.
The trustee has a good working relationship with the district board, district administration, and
county superintendent of schools. Consequently, the trustee can provide direction and insight early
in the decision making process to help prevent issues that would require the use of stay or rescind
authority. Stay or rescind authority is typically used when a district’s board or its staff have not
cooperated with the trustee’s direction or have approved actions that are not in the district’s opera-
tional or fiscal best interests. The trustee has not had to use stay or rescind authority since FCMAT’s
last visit, which indicates the effectiveness of the trustee and the willingness of the district’s board
and superintendent to exit from receivership.
10. What is the status of the district's recovery?
The district's financial and personnel management processes are strong and continue to evolve.
The district, trustee, and county superintendent of schools all acknowledge that the district has not
effectively addressed its low pupil achievement.
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The county superintendent of schools has clearly organized district oversight in the five interrelated
areas that caused the receivership and has fostered open communication with the district in each of
these areas. The district continues to be well positioned financially, and fund balance and reserves
are at more than the minimums. The district has processes for projecting revenues, average daily
attendance, and expenditures. If the district’s governing board continues to follow the chief busi-
ness official’s recommendations regarding fiscal matters and collective bargaining affordability, the
district’s fiscal status should remain positive and strong.
Concerns remain about providing programs and services for students at the expense of a conserva-
tive budget mindset. The high turnover in the district superintendent position has created an unsta-
ble environment, creating a leadership void and causing a lack of progress on increasing student
academic achievement. This has resulted in inadequate support to meet the needs of all students.
Because the indicators of student performance continue to demonstrate a need for improvement,
the district should focus on increasing services to students while maintaining a balanced budget.
The district should invest in multiple leadership positions to lead its instructional programs and
increase student achievement.
11. On or before October 31, has the governing board of the school district prepared a report on the
financial condition of the school district, which the trustee has reviewed and the county superin-
tendent of schools has subsequently received a copy of? (Education Code Section 41321).
The district completed a report, which was reviewed by the trustee and subsequently received by
the county superintendent of schools. FCMAT provided a sample of a report for future reference,
which the district and county superintendent will use for future reporting.
12. How has the county office addressed elements in the initial review that were designated as a
"No" and were included in the final report?
County superintendent of schools staff have continued to ensure that the areas identified as defi-
ciencies in the initial review continue to be addressed in the fiscal review checklists and oversight
documents. Internal procedures and areas of focus were modified after FCMAT’s last visit, which
resulted in increased engagement with the school district.
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General Conclusions and Recommendations
The Monterey County Superintendent of Schools is leading a focused effort to support the district in
achieving long-term financial solvency and has increased its focus, attention, and efforts since FCMAT’s last
annual visit. A process has been clearly articulated for the district to monitor and support implementation of
actions to address deficiencies identified in the comprehensive review. The district’s financial condition has
remained sound. Unfortunately, the district has struggled with stable leadership and has experienced high
turnover in the superintendent position. This has unintended consequences, including a lack of improved
academic achievement.
Because of this, the county superintendent of schools should:
1. Continue to implement its process to support and monitor the district's implementation of
the comprehensive review.
2. Focus the district on improving pupil achievement.
3. Support the district in its process to recruit, hire and retain a qualified permanent
superintendent.
4. Encourage the district to invest in multiple instructional leaders: one to oversee policy
and governance and others to manage instructional practices, improve student academic
achievement, and increase outcomes for students.
5. Request that the trustee report the district’s progress toward implementing the outstanding
findings and recommendations in the comprehensive review to the county superintendent
and other interested parties at least annually.
6. Request that the trustee use FCMAT’s FHRA tool to guide his work with the district.
The transition from state to county administration due to changes in law (AB 1840) is continuing to evolve.
In part, the purpose of these annual evaluations is to clarify the roles and responsibilities of all the con-
cerned and involved parties so that they can assist and support the district’s recovery and thereby appro-
priately focus the organization on providing the best and most equitable educational experience for every
child. This report attempts to assess the district’s recovery status and the essential support provided by
the county superintendent’s office and establish a baseline for the next annual evaluation, which will occur
approximately one year from the publication of this report.
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Appendices
Appendix A: Trustee Roles and Responsibilities
Appendix B: Study Agreement
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Appendix A: Trustee Roles and Responsibilities
Trustee
Roles and Responsibilities
Acceptance by a district of an emergency state apportionment made pursuant to Section 41320
constitutes an agreement by the district that a trustee will be appointed to ensure the district’s fiscal
recovery and solvency per Education Code Section 41320.1. The trustee shall be appointed jointly by
the county superintendent, the Superintendent of Public Instruction (SPI), and the president of the State
Board of Education. The trustee should have recognized expertise in management and finance, shall
report directly to the county superintendent, and shall serve until the district has adequate fiscal
systems and controls in place and the SPI has determined that the district’s future compliance with the
fiscal plan approved for the district pursuant to Section 41320 is probable.
The trustee shall monitor and review the operations of the district, and shall perform the following
functions:
1. Serve in a fiscal oversight capacity until the district has adequate fiscal systems and controls in
place, and future compliance with the approved recovery plan is probable.
2. Provide advice and make recommendations to district staff and governing board members
regarding budgetary, fiscal, or other issues that may affect the financial condition of the district.
3. Attend all meetings of the governing board and review all governing board materials prior to
each board meeting to determine if any items or intended action will have a negative fiscal
impact on the district’s financial condition.
4. Stay or rescind an action of the governing board of the district or of the personnel commission
where, in the judgment of the trustee, the action may adversely affect the financial condition of
the district or be contrary to the district’s approved recovery plan.
5. Notify the county superintendent of schools when a stay or rescind of a governing board
decision is made. The county superintendent then shall notify the Superintendent and the
president of the state board or his or her designee within five business days.
6. Monitor the financial projections and cash balances of all district funds for the current and two
subsequent fiscal years, and, if necessary, assist district staff in preparing these projections.
7. Monitor all collective bargaining activity and review all proposals being considered, including
the resulting fiscal impact.
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8. Regularly meet with the district superintendent and chief business officer to obtain updates on
the district’s efforts to reduce expenditures or enhance revenues.
9. Assist the county superintendent with establishing timelines and prescribing formats for reports
and other materials to be used to monitor and review the operations of the district.
10. Communicate openly and timely with the county superintendent, district staff, governing board,
and community, and promptly inform the county superintendent of critical issues or incidents.
11. Review and approve the district’s required annual report of the financial condition of the
district, including all of the following information:
(1) Specific actions taken to reduce expenditures or increase income, and the cost savings
and increased income resulting from those actions, to ensure the revisions are consistent
with the district’s needs and recovery plan.
(2) The adopted budget for the current fiscal year.
(3) Reserves for economic uncertainties.
(4) Status of employee contracts.
(5) Obstacles to the implementation of the adopted recovery plan.
12. Using the Fiscal Crisis and Management Assistance Team’s (FCMAT’s) Fiscal Health Risk
Analysis, annually evaluate the district’s risk of insolvency in the current and two subsequent
fiscal years and communicate findings to the county superintendent.
13. Determine, with concurrence from the county superintendent and SPI, that future compliance
by the district with the approved recovery plan is probable so that the district can meet its
future financial obligations.
14. Provide regular updates to the county superintendent regarding the progress of the district
toward fiscal stability.
15. Consult with, and seek recommendations from, the county superintendent, the SPI, and
FCMAT in ensuring the fiscal recovery and solvency of the district.
16. With approval from the county superintendent, the SPI, and the president of the state board,
retain the authority and responsibilities of an administrator, as set forth in Education Code
Section 41325.
17. Assist in related matters as needed regarding the district’s fiscal recovery and solvency, in
accordance with Education Code Sections 41320.1, 41321, and 41322.
18. Review the financial and budgetary conditions of the district, including an analysis of internal
controls, and determine if it may be unable to meet its financial obligations for the current or
two subsequent fiscal years, or should receive a qualified or negative interim financial
certification.
19. Meet with appropriate district staff, as needed, to assess fiscal health, organizational structure
and staffing, effectiveness of internal controls, and other related concerns.
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20. Consult with the governing board on fiscal and budgetary matters, facilities projects, debt
obligations and other operational areas, as needed.
21. Provide recommendations for improvements in district processes related to the budget,
including position control, areas for cost containment, reducing unrestricted contributions from
the general fund, etc.
22. Confirm that the district conducts its business operations in compliance with statutory
requirements and within acceptable legal and professional standards.
23. Advise county superintendent regarding potential action to improve or protect the fiscal
solvency of the district.
24. Provide additional support, technical assistance, professional learning, and advice outlined in
the five operational areas defined by Education Code Section 41327.1 in the Long Range
Recovery Plan (LRRP). Focus on assisting the district in addressing recommendations
identified in the LRRP to support maintaining future solvency, organizational effectiveness and
recovery. Report annually to the county superintendent regarding the progress made by the
district in implementing LRRP.
Related Education Code Sections: 41320, 41320.1, 41322
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Appendix B: Study Agreement
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