Trinity County Office of Education Report

Trinity County Office of Education Special Education Local Plan Area Review December 7, 2016 Joel D. Montero Chief Executive Officer Fiscal crisis & ManageMent assistance teaM December 7, 2016 Bettina Blackwell, Superintendent Trinity County Office of Education 201 Memorial Drive Weaverville, CA 96093 Dear Superintendent Blackwell: In June 2016, the Trinity County Office of Education and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement to conduct a management assistance review. Specifically, the agreement states that FCMAT will perform the following: 1. Review the current Trinity Special Education Local Plan Area (SELPA) allocation funding model and make recommendations for a more equitable distribution to districts, if needed. In addition, review the bill-back model. This final report contains the study team’s findings and recommendations in the above areas of review. FCMAT appreciates the opportunity to serve you and extends thanks to all the staff of the Trinity County Office of Education and the SELPA member districts for their cooperation and assistance during fieldwork. Sincerely, Joel D. Montero Chief Executive Officer Fiscal crisis & ManageMent assistance teaM i TABLE OF CONTENTS Table of Contents About FCMAT .........................................................................................iii Introduction ............................................................................................1 Background ......................................................................................................1 Study and Report Guidelines .....................................................................1 Study Team.......................................................................................................2 Executive Summary ..............................................................................3 Findings and Recommendations .....................................................5 Special Education Local Plan ......................................................................6 SELPA Funding ...............................................................................................6 Accounting and Budget Development ..................................................9 Reporting and Timelines ...........................................................................10 Charter Schools.............................................................................................11 Appendices ............................................................................................15 TriniTy CounTy offiCe of eduCaTion ii Fiscal crisis & ManageMent assistance teaM iii ABOUT FCMAT About FCMAT FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify, prevent, and resolve financial, human resources and data management challenges. FCMAT provides fiscal and data management assistance, professional development training, product development and other related school business and data services. FCMAT’s fiscal and manage- ment assistance services are used not just to help avert fiscal crisis, but to promote sound financial practices, support the training and development of chief business officials and help to create efficient organizational operations. FCMAT’s data management services are used to help local educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and inform instructional program decisions. FCMAT may be requested to provide fiscal crisis or management assistance by a school district, charter school, community college, county office of education, the state Superintendent of Public Instruction, or the Legislature. When a request or assignment is received, FCMAT assembles a study team that works closely with the LEA to define the scope of work, conduct on-site fieldwork and provide a written report with findings and recommendations to help resolve issues, overcome challenges and plan for the future. FCMAT has continued to make adjustments in the types of support provided based on the changing dynamics of K-14 LEAs and the implementation of major educational reforms. Studies by Fiscal Year 90 80 70 60 50 40 30 20 10 0 92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15 TriniTy CounTy offiCe of eduCaTion seidutS fo rebmuN FCMAT also develops and provides numerous publications, software tools, workshops and professional development opportunities to help LEAs operate more effectively and fulfill their fiscal oversight and data management responsibilities. The California School Information Services (CSIS) division of FCMAT assists the California Department of Education with the implementation of the California Longitudinal Pupil Achievement Data System (CALPADS). CSIS also hosts and maintains the Ed-Data website (www.ed-data.org) and provides technical expertise to the Ed-Data partnership: the California Department of Education, EdSource and FCMAT. FCMAT was created by Assembly Bill (AB) 1200 in 1992 to assist LEAs to meet and sustain their financial obligations. AB 107 in 1997 charged FCMAT with responsibility for CSIS and its state- wide data management work. AB 1115 in 1999 codified CSIS’ mission. iv ABOUT FCMAT AB 1200 is also a statewide plan for county offices of education and school districts to work together locally to improve fiscal procedures and accountability standards. AB 2756 (2004) provides specific responsibilities to FCMAT with regard to districts that have received emergency state loans. In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became law and expanded FCMAT’s services to those types of LEAs. Since 1992, FCMAT has been engaged to perform more than 1,000 reviews for LEAs, including school districts, county offices of education, charter schools and community colleges. The Kern County Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the state budget and a modest fee schedule for charges to requesting agencies. Fiscal crisis & ManageMent assistance teaM 1 INTRODUCTION Introduction Background Located in the rural town of Weaverville in Northern California, the Trinity County Office of Education (county office) serves nine school districts and operates one special education program, all of which participate in the Trinity Special Education Local Plan Area (SELPA). The county has a total of 1,522 students this school year, which is an increase of 59 students over 2015-16 and the first increase since 2006-07, excepting a very small increase in 2010-11. Trinity Alps Unified is the largest school district in the county, with 676 students according to the most recent data certified by the California Department of Education (CDE). The two smallest school districts, with 10 students each, are Coffee Creek Elementary and Trinity Center Elementary. On June 7, 2016, the county office and the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an agreement for FCMAT to review the Trinity SELPA’s funding alloca- tion model. Specifically, the study agreement states that FCMAT will perform the following: 1. Review the current Trinity Special Education Local Plan Area (SELPA) allocation funding model and make recommendations for a more equitable distribution to districts, if needed. In addition, review the bill-back model. Study and Report Guidelines FCMAT visited the county office and districts on September 26-27, 2016 to conduct interviews, collect data and review documents. This report is the result of those activities and is divided into the following sections: I. Special Education Local Plan II. SELPA Funding III. Accounting and Budget Development IV. Reporting and Timelines V. Charter Schools In writing its reports, FCMAT uses the Associated Press Stylebook, a comprehensive guide to usage and accepted style that emphasizes conciseness and clarity. In addition, this guide empha- sizes plain language, discourages the use of jargon and capitalizes relatively few terms. TriniTy CounTy offiCe of eduCaTion 2 INTRODUCTION Study Team The study team was composed of the following members: Deborah Deal, CICA, CFE Jackie Martin* FCMAT Intervention Specialist Assistant Superintendent, Chief Business Los Angeles, CA Official Atascadero Unified School District Atascadero, CA John Lotze Dr. Jackie Kirk-Martinez FCMAT Technical Writer FCMAT Consultant Bakersfield, CA Pismo Beach, CA *As a member of the study team, this individual was not representing her employer but was working solely as an independent contractor for FCMAT. Each team member reviewed the draft report to confirm its accuracy and to achieve consensus on the final recommendations. Fiscal crisis & ManageMent assistance teaM 3 EXECUTIVE SUMMARY Executive Summary The Trinity County Office of Education (county office), Trinity Special Education Local Plan Area (SELPA) and the county and SELPA’s nine school districts requested an analysis of the SELPA’s Assembly Bill (AB) 602 special education allocation plan and recommendations for an equitable allocation of funds and distribution of excess costs. The SELPA has tried unsuccessfully a number of times to change the allocation model over the past two years. Approved amendments to the original plan although formally approved have not been memorialized in formal SELPA plan documents. Although the current local plan is a fair and equitable distribution model, it is cumbersome and difficult to understand and is clouded with other issues that are external to the plan components, including large variances between initial estimated and final actual expenditures, and a lack of adherence to reporting deadlines. The current allocation plan is developed in a Microsoft Excel spreadsheet that is difficult to follow, and member districts do not fully understand how the plan works. Member districts report that a revised Excel spreadsheet intended to provide clarity led to more confusion and additional questions. Districts report inconsistent and inaccurate accountability for services and questioned the SELPA’s direct usage calculations. Intervals of more than a year between budget estimates and final expenditure calculations have led to large variances between the two, which affect districts’ budgets many months after their books should be closed for the fiscal year. During FCMAT’s fieldwork, many districts reported that their books were not closed at the end of September because districts did not have the final allocations for revenue and distribution of expenditures for their individual districts. A lack of adequate supporting documents and clear explanations of why final calculations differ from previous estimates have created a lack of trust between member districts and the county office’s chief business official (CBO). The roles and functions of the county office and the SELPA staff members should be distin- guished and delineated from one another; however, county office and SELPA services are not separate and distinct, which result in confusion about direct services for member districts as opposed to SELPA services paid for under the allocation plan. The California Heritage Youth Build Academy (CHYBA) charter school in Shasta County has approximately 80 students, all of whom reside outside of Trinity County. The Trinity county office’s governing board authorized the charter school for the 2016-17 fiscal year. Attempts to include the charter school as a SELPA member gave rise to concerns from member districts that they would lose already limited special education funding if this occurred. TriniTy CounTy offiCe of eduCaTion 4 Fiscal crisis & ManageMent assistance teaM 5 FINDINGS AND RECOMMENDATIONS Findings and Recommendations County offices of education support school districts by performing a variety of tasks that can be done more efficiently and economically at the county level. This includes services such as assisting with new curricula; staff development and training programs; instructional procedures; the design of business and personnel operating systems; and many other functions to help districts meet changing needs and requirements. Centralized county or regional services for students with highly specialized needs provide the advantage of economies of scale, especially in large rural areas such as Trinity County where several small school districts encompass several hundred square miles. Regional programs serve children and young adults with exceptional needs from multiple school districts, providing them with specialized programs that would be financially disadvantageous for a single school district to offer. These include programs for students who are visually impaired, deaf and hard of hearing; students in vocational education; students in programs for youths at risk of failure; and instruc- tion for students in juvenile detention facilities. The California Department of Education (CDE) provides guidance on state and federal laws passed between 1970 and 1987 that increased special education services; these include federal public laws 93-112, 94-142, and 99-457. In response to these laws and other mandates, California passed legislation that requires school districts and regional agencies to establish SELPAs to meet the needs of children with disabilities. According to the CDE at: http://www.cde.ca.gov/sp/se/as/caselpas.asp, these laws and regula- tions promote changes and procedures leading to the following: • Accountability • Annual Reviews of Progress • California Special Education Management Information System (CASEMIS) Reporting • Career Training • Community Involvement and Support • Compliance Reviews • Coordination of Resources Among Districts by Regions • Desired Results Developmental Profile (DRDP) Assessment and Data Reporting • Due Process Rights • Educational Benefit • Full Services to All Students with Disabilities • Guaranteed Equality of Access • Improved Self-esteem for Children with Disabilities • Increased Parent Participation • Individualized Education Programs (IEPs) • Less Restrictive Environment • Local Governance Systems TriniTy CounTy offiCe of eduCaTion 6 SPECIAL EDUCATION LOCAL PLAN • Program Evaluation • Quality Program Reviews • Social Acceptance of Children with Disabilities • Staff Development Programs • State Performance Plan Indicator Data Collection • Transition from School to Post-Secondary Education and Employment Special Education Local Plan The CDE indicates that legislation enacted in 1977 mandated that all school districts and county school offices “form consortiums in geographical regions of sufficient size and scope to provide for all special education service needs of children residing within the region boundaries” (www. cde.ca.gov/sp/se/as/caselpas.asp). California has 122 regions, also called SELPAs, each of which creates a local plan for how special education services will be provided. The development of each region’s local plan is a unique and collaborative process involving local school districts and county offices and is designed to facilitate programs that guarantee equal opportunity for all students. The Trinity SELPA’s local plan has not been formally updated since 2007-08. Many agreements have been approved by member districts and county office staff during that time; however, the formal local plan does not include these. The local plan also does not include changes in funding resulting from AB 114, Chapter 43, Statutes of 2011, which changed several sections of the Government Code (GC) to transfer the responsibility for mental health services from individual county mental health programs to schools. According to the CDE at http://www.cde.ca.gov/sp/se/ac/ab114twg.asp AB 114 gave schools sole responsibility “for ensuring that students with disabilities receive special educa- tion and related services to meet their needs in accordance with Individuals with Disabilities Education Act (IDEA) of 2001.” A funding source for mental health appropriated to the Trinity SELPA has not been included in its local plan or presented to member districts for discussion. SELPA Funding Federal and State Revenue The state allocates special education funds to SELPAs based on SELPAwide average daily atten- dance (ADA), with annual cost-of-living increases as well as adjustments for increases or decreases in SELPAwide ADA. Special education funding is the second-largest source of funding to school districts (after Local Control Funding Formula apportionments from the state) but falls far short of what they need to serve students with disabilities and comply with both federal and state law. California distributes federal and state special education funding through SELPAs, and local school districts almost always have to supplement this funding with money from their unrestricted general fund to provide adequate special education services. SELPA members interviewed, including districts and the county office-operated program, expressed a desire to establish a revenue distribution plan that is clearly defined and equitable. Documents reviewed and interviews with employees confirm that the revenue distribution is based on SELPAwide enrollment as reported in October in the official California Longitudinal Pupil Achievement Data System (CALPADS) report, also referred to as the Fall 1 count. Fiscal crisis & ManageMent assistance teaM 7 SELPA FUNDING Allocation Plan The Trinity SELPA’s formal 2007-08 allocation plan is based on a 90/10 cost distribution model, under which 90% of the expense for each student is paid by all member districts and 10% by the district in which the student resides. The majority of member districts were opposed to this allocation plan and voted two years ago to implement a revised allocation model based on a combination of cost methodologies. As a result, the current allocation plan is based on both a direct-service and cost-sharing approach: expenses for psychologists and nurses are based on CALPADS-certified enrollment and distributed among member districts; occupational, physical and speech therapy costs are deter- mined based on estimated average staffing costs and subsequently invoiced based on actual use. Clear and Equitable Funding Allocation The SELPA needs a clearly defined and easy to understand funding allocation plan that provides predictable, timely and accurate information. Effective allocation plans are built on shared prin- ciples that foster fairness and equity. The county office’s CBO will need to review regularly the usage of bill-backs for direct services and staffing, and report this information to member districts in accordance with a predetermined schedule. The SELPA’s governance team, composed of school district superintendents and county office personnel, has tried unsuccessfully a number of times to change the allocation model over the past two years. Approved amendments to the original plan although formally approved have not been memorialized in formal SELPA plan documents. This has left member districts and county office staff frustrated. The SELPA members’ mistrust has increased over time, mainly because of the unpredictability of final financial information, which is commonly generated many months after projections and which as a result contains large variances between estimated and actual expenditures as well as insufficient explanations regarding them. Having a neutral facilitator help the SELPA and its members develop a new allocation plan could help ensure open and clear communication that will benefit all parties. After an allocation plan is developed and agreed upon, the SELPA will need to continue coordi- nating regular business meetings and meetings with SELPA members to review updated financial information and discuss requests for changes as circumstances warrant. Several individuals interviewed reported that agreements were made in meetings but have not been formalized in the allocation plan document. It would benefit the SELPA to make sure all meetings include minutes and are preceded by a formal distribution of information about the meeting date, time and location. Modifications to the allocation plan that are agreed to and voted on by the governance team need to be immediately included in the local plan and formally updated in the local plan at least annually. Documents from the county office and the SELPA and interviews with district staff indicate that the funding allocation spreadsheets the county office’s CBO prepares are voluminous, overly detailed and lacking in clarity. Member districts were unable to state the amounts they receive for psychological, nursing and speech services and were uncertain whether the bill-backs for these services are correct or consistently applied. This added to their uncertainty and mistrust. It would benefit the SELPA and its members if the allocated expenditures for SELPA adminis- tration, psychologists and nurses were separated and distinguished from the fee-based (bill-back) schedule for direct services such as speech, occupational and physical therapy, which are charged based on actual usage. This would better reflect and make more clear how the services are actually provided and their allocated costs. FCMAT created a sample allocation plan using the Trinity TriniTy CounTy offiCe of eduCaTion 8 SELPA FUNDING SELPA’s 2015-16 data; this document is in appendix A of this report. The sample funding allo- cation plan distributes the special education funding and the allocated countywide service costs using the October 2015 CALPADS enrollment. The major components of the FCMAT sample allocation plan are as follows: a. Special Education Transportation The county office’s Local Control Funding Formula (LCFF) add-on funding for special education transportation is allocated based on the number of pupils transported. b. Shared Costs This includes allocated countywide service costs for the SELPA administrative fees, psychologists, and nursing services. c. Out-of-Home Care The out-of-home care allocation is used to offset the SELPA’s costs for these services. d. Special Education Extraordinary Expense Reserve (SEEER) The sample includes the amount each district would contribute to the countywide pool for the SEEER. Because the Trinity SELPA has many small school districts, it would benefit the SELPA and its members to have a separate extraordinary cost pool in case a member has a student or students who require high-cost services. Without such a pool, one residential nonpublic school placement or expensive due process settlement could cause significant financial hardship. FCMAT’s sample allocation plan includes a column titled Reallocated Unspent in case a SELPA member has special education carryover and the SELPA decides to reallocate carryover. The sample allocation plan does not include direct services charged based on use. It would be a better practice for the SELPA to develop and maintain a separate fee schedule for direct services provided by the county office so that the SELPA members can be invoiced directly for these based on actual use of services. It would also be best if the fee schedule calculation included a census date or dates on which the use data is gathered to determine fees and use factors such as identified number of students, number of annual student hours, or distribution based on assigned FTE to calculate costs. Having the fee schedule follow the timelines suggested in the Reporting and Timelines section below for the projected direct services use costs would allow the districts to adjust their budgets in time if needed. It is a best practice to attach to the invoice any documents that verify services provided. Appendix B contains a sample fee schedule for speech services using the SELPA’s 2015-16 expenses provided to FCMAT. Formal Meetings When developing the budget and ongoing best practices, it would benefit the SELPA to schedule monthly formal meetings that include administrators from the county office’s special education, business and human resources departments as well as representatives from member districts. It would also benefit the SELPA to schedule simultaneous but separate meetings of business staff and of superintendents and/or principals, followed by a joint meeting of all SELPA members. Best practice is to send attendees requests for agenda items at least one week before a meeting and post the agenda publicly two days before the meeting. Business meeting agendas could include the following items for discussion: • Revenue allocations for state and federal funding • Estimates for predetermined set-asides for extraordinary cost risk pools Fiscal crisis & ManageMent assistance teaM 9 ACCOUNTING AND BUDGET DEVELOPMENT • Requests for payment of extraordinary costs or mental health services • Requests for educationally-related mental health needs • Review of the most recent direct cost charges • Review of updated shared costs and projections • Enrollment projections or actual Fall 1 enrollment • Budget development and monitoring • Impact of requests for additional county office staff or changes in assignments • Nonpublic school and/or nonpublic agency contracts, invoices and new placements • Interim or end-of-year financial reporting for maintenance of effort calculations Superintendent/principal meeting agendas could include the following items for discussion: • Identified student counts • Identified needs • Due process or complaint issues • Staff caseloads Joint meetings should include issues that could have a fiscal impact, and updates from the indi- vidual meetings. Accounting and Budget Development The SELPA’s budget is not recorded separately from the county office’s budget in the accounting system. The recording of transactions and budgeting needs to be separate, and components of the SELPA budget need a unique account code structure to facilitate monitoring and reporting of the SELPA’s operating budget, low-incidence funds, mental health funds, and SEEER. This would make it easier to report to SELPA members at periodic meetings and as needed, close the books at fiscal year-end, and allocate costs to member districts. Procedure 755 in the California School Accounting Manual (CSAM) has guidance for estab- lishing a locally-defined fund code that would automatically roll into Fund 01 for reporting purposes. A separate fund, such as Fund 10, could be used for the pass-through of state and federal revenues to member districts. If Fund 10 is used as a pass-through fund, it should have a zero balance at year-end closing. The county office and SELPA need to clearly define and differentiate SELPA roles, functions, responsibilities and personnel from those of the county office, and define how business services responds to the needs of both. Because the county office is small and has limited staff, many staff members are paid for from more than one source of funding. When developing budgets, the SELPA and the county office need to determine the percentage of a staff member’s time to allocate to SELPA services and to county office services. In situations like this, it is best to allocate funding based on initial estimates but follow up with a time study like those required for positions funded by multiple federal sources. The table below shows how the SELPA and county office budgets could be prepared. TriniTy CounTy offiCe of eduCaTion 10 REPORTING AND TIMELINES Description SELPA County Office Multi-funded position. SELPA Director. Special education county office director. Multi-funded position. SELPA Executive Secretary. Special education county office secretary. Multi-funded activities. Special education information system (SEIS). Special education information system (SEIS). Invoiced to member districts based on All FTE positions providing service to students formula. SELPA administrative fee/dues. hired through the county office. Preschool budget – County operated pro- Services are billed back based on usage. SELPA direct operating expenses. gram. Services are billed back based on usage. Psychologist and nursing. Psychologist and nursing. Direct services for speech, occupational and Services are billed back based on usage. Low-incidence funding. physical therapy Services are billed back based on usage. Allocated countywide services. Educationally-related mental health funding. Requests must be approved by SELPA Any agreed upon specialized pools such as governance team. the current SEEER. After the SELPA’s governance team approves the SELPA’s budget, additional requests for funding increases or payment of extraordinary costs can be presented to the governance team for formal approval. These requests need to include an explanation of the fiscal impact on member districts, and they should be posted for SELPA members at least two business days before the meeting. Educationally-Related Mental Health Funding FCMAT’s review of financial records revealed carryover balances of more than $86,600 in educationally-related mental health funding. A plan to spend this money was proposed but not formally adopted; therefore, the funds have been reserved for future use. Uses of these restricted funds must qualify under strict expenditure guidelines. The SELPA governance team will need to set priorities for the use of federal and state mental health funding in accordance with expenditure guidelines. The following priorities would meet these guidelines: • Continue its contract with Trinity County for behavioral health services • Nonpublic school mental health placements • Supplement behavioral support services for districts with students who have extreme behavioral and emotional challenges Reporting and Timelines SELPA Reporting The county office CBO is responsible for financial accounting and reporting for county office services, including both county office internal services and financial services support to school districts throughout the county. The CBO also oversees and develops the SELPA allocation plan, distributes allocations to member districts, and is responsible for federal and state reporting and helping small school districts with year-end closing. For member districts to receive information for budgeting and planning purposes, it is essential that they complete reports by agreed-upon deadlines. The county office business department and the district CBOs or business managers will need to jointly establish a timeline for special education budget projections, SELPA plan allocations, invoices for direct services, and year-end unaudited actuals reporting. Fiscal crisis & ManageMent assistance teaM 11 CHARTER SCHOOLS Districts report that the accounting for special education services is inconsistent and inaccurate, and they questioned the direct usage calculations. Often more than a year goes by between budget estimates and final expenditure calculations. This has led to large variances, which affect districts’ budgets many months after the books should be closed for the fiscal year. A lack of both adequate supporting documents and clear explanations of how and why the final calculations differ from previous estimates have created a lack of trust between member districts and the county office CBO. The CBO needs to provide clear, timely and understandable explanations and accounting for services and use of services listed on a student’s IEP to support the amounts being charged for direct services. Updated estimates for cost allocations and usage also need to be accurate, understandable and provided on time at predefined intervals through the fiscal year. All estimates need to be based on the latest information available. The table below shows a sample timeline. Activity Due Date Initial estimates for the upcoming fiscal year April 30 Revised projections to include CALPADS enrollment October 31 Updated projections and actual billings January 31 Estimated Actuals to include P-2* certifications May 15 Final allocations to include state certifications No later than July 15 *The P-2 is a critical attendance reporting period used to determine significant funding based on the Local Control Funding Formula, funding for special education, and funding calculations for many other programs for the fiscal year. When final certifications of federal and state revenues are received from the CDE at the end of June, this information and a full accounting needs to be distributed to SELPA members immedi- ately, and a final expenditure report needs to be provided no later than August 1. In the last two fiscal years, the county office CBO has been unable to make final calculations until late September or October, which delayed member school districts’ closing of their books until after the September 15 deadline. Education Code 42100 (a) states: On or before September 15, the governing board of each school district shall approve, in a format prescribed by the Superintendent of Public Instruction, an annual state- ment of all receipts and expenditures of the district for the preceding fiscal year and shall file the statement, along with the statement received pursuant to subdivision (b), with the county superintendent of schools. On or before October 15, the county super- intendent of schools shall verify the mathematical accuracy of the statements and shall transmit a copy to the Superintendent of Public Instruction. Each district is required to have its unaudited actuals approved by its governing board and sent to the county office by September 15; the county office is required to review the unaudited actuals and submit them to the state by October 15. To comply with this law, the county office needs to provide the districts with the information they need to close their books on time. Charter Schools California Heritage Youth Build Academy (CHYBA) is a charter school in Shasta County that has approximately 80 students. The Trinity County Office of Education’s governing board authorized the CHYBA charter school for the 2016-17 fiscal year under Education Code Section TriniTy CounTy offiCe of eduCaTion 12 CHARTER SCHOOLS 47605.1 (g)(2). Although the county office has one dependent charter school for independent study, CHYBA is the first independent charter school authorized by the county office. The county office and SELPA staff recommended including CHYBA in the SELPA allocation plan; however, the SELPA agreement requires approval from all SELPA members. The county office requested that each member district’s school board approve a resolution in favor of including CHYBA, but this did not occur because many districts had concerns about the poten- tial negative effect this would have on the distribution of special education funding. Because of this, CHYBA can apply to other SELPAs throughout the state and receive direct services from the Trinity County Office of Education, but it cannot become a member of the Trinity SELPA until all member districts approve. Based on CHYBA’s 2015-16 second interim ADA, including it in the SELPA would have increased SELPA funding by $25,036, but CHYBA would have received $52,632 under the SELPA’s distribution model, resulting in overall loss of $27,596. The reason for this is that state special education funding is based on attendance but allocations of SELPA’s state funding to member districts are based on enrollment, and CHYBA’s October 2015 CALPADS enrollment of 70 students was significantly greater than its second interim ADA of 56.24, so its ADA was only 80.3% of enrollment. The SELPA will need to carefully evaluate the potential effects of adding new members for at least the next three years to determine the long-term impact, because state special education funding is based on countywide attendance in either the current or prior year (refer to Appendix C and compare it to Appendix A). Recommendations The SELPA should: 1. Develop a clear and easy to understand funding allocation plan that provides predictable, timely and accurate information and that is built on principles of fairness and equity. 2. Ensure that the county office CBO reviews direct service usage and resulting bill-backs and staffing regularly and reports this information to its members in accordance with a predetermined schedule. 3. Ensure that its governance team considers using a neutral facilitator to help implement a new allocation plan. 4. Coordinate and schedule regular SELPA business and superintendent/prin- cipal meetings. Distribute materials and requests for agenda items, and post agendas publicly, before each meeting date. 5. Include SELPA allocation plan amendments in its local plan immediately, and have its governance team formally updated the local plan annually. 6. Ensure that its governance team considers creating a separate extraordinary cost pool. 7. Ensure that its allocation plan includes all funding, including educational- ly-related mental health funding. Fiscal crisis & ManageMent assistance teaM 13 CHARTER SCHOOLS 8. Separate the different funding sources for SELPA and COE budgets in the account code structure, and code positions to these budget accounts; follow Procedure 755 in the CSAM. 9. Provide its member districts with clear accounting for and information about direct services in a timely manner at predetermined intervals throughout the fiscal year. 10. Carefully evaluate the potential effects of adding new members to the SELPA. 11. Clearly define county office and SELPA staff roles. 12. Ensure that the governance team approves the SELPA’s budget, additional requests for funding increases, and payment of extraordinary costs. 13. Ensure that the governance team sets priorities for mental health funding. TriniTy CounTy offiCe of eduCaTion 14 Fiscal crisis & ManageMent assistance teaM 1155 APPENDDRICAEFST Appendices Appendix A Sample Funding Allocation Model Appendix B Sample Fee Schedule for Direct Services Appendix C Sample Funding Allocation Model including CHYBA Appendix D Study Agreement TriniTy CounTy offiCe of eduCaTion 1166 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 1177 APPENDDRICAEFST Appendix A Sample Funding Allocation Plan TriniTy CounTy offiCe of eduCaTion 1188 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 1199 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 2200 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 2211 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 2222 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 2233 APPENDDRICAEFST Appendix B Sample Fee Schedule TriniTy CounTy offiCe of eduCaTion 2244 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 2255 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 2266 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 2277 APPENDDRICAEFST Appendix C Sample Funding Allocation Plan (CHYBA) TriniTy CounTy offiCe of eduCaTion 2288 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 2299 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 3300 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3311 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 3322 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3333 APPENDDRICAEFST Appendix D Study Agreement TriniTy CounTy offiCe of eduCaTion 3344 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3355 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 3366 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3377 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion 3388 DARPPAEFNTDICES Fiscal crisis & ManageMent assistance teaM 3399 APPENDDRICAEFST TriniTy CounTy offiCe of eduCaTion Fiscal crisis & ManageMent assistance teaM