After several meetings and much debate over the past year, the State Board of Education (SBE) is expected to finalize rules tomorrow that will govern school district spending in California for years to come. When Governor Brown and the Legislature created California’s new education funding formula, the Local Control Funding Formula (LCFF), in July of 2013 they deferred to the SBE key decisions regarding accountability — specifically, how to ensure that school districts spend LCFF dollars to provide additional services for disadvantaged students. Earlier this year, the SBE adopted emergency regulations for how schools could spend LCFF dollars in 2013-14. These temporary rules inspired a spirited debate that led to tomorrow’s expected adoption by the SBE of permanent LCFF spending regulations. At the core of this debate has been how to strike the balance between ensuring that LCFF dollars are used to support the disadvantaged students for whom they are intended and providing school districts more authority over how to spend those dollars. The proposed permanent regulations the SBE is likely to adopt tomorrow both gives school districts greater latitude over how to spend LCFF dollars and requires them to show less about how they spend those dollars than many advocates for disadvantaged students had wanted.
The law establishing the LCFF required the SBE to adopt regulations that govern the spending of dollars intended to support disadvantaged students as well as a template for a Local Control and Accountability Plan (LCAP), which school districts must use to show compliance with LCFF spending rules. During the past several months, the SBE has held hearings on the proposed spending regulations and the LCAP template. In response to extensive public comment and testimony, the Board made several improvements to the regulations, such as requiring a higher level of student participation in the development of LCAPs. However, although advocates for disadvantaged students had called for greater transparency, the SBE is expected to adopt regulations tomorrow that will make it difficult for education stakeholders to know whether school districts meet the requirement to use LCFF dollars generated by disadvantaged students to increase or improve services for these students.
As we blogged about in advance of the first meeting where the SBE took action on LCFF’s spending rules, we believe the regulations should have abided by two important principles: establishing a baseline and ensuring transparency. For stakeholders to understand the extent to which LCFF dollars are used to support disadvantaged students, the regulations should require school districts to clearly report a baseline spending level. While the regulations the SBE is expected to adopt tomorrow do require school districts to use prior-year spending on disadvantaged students as a starting point for estimating the level of support going forward, they do not require transparent reporting of this baseline level of spending. Unfortunately, the SBE rejected requests for this basic level of transparency in its response to comments that had been submitted by several advocates for disadvantaged students. As a result, local stakeholder engagement will be critical to ensure that the LCFF dollars generated by disadvantaged students are used to support them. For example, parent advisory committees could use the requirement that school districts respond in writing to their requests for information — during the process of adopting or updating LCAPs — in order to get information on the local use of LCFF dollars.
The next stage of LCFF rulemaking requires the SBE to adopt evaluation rubrics to assess school district and schoolsite performance based on standards established by the SBE. The Legislature required the SBE to adopt evaluation rubrics by October 1, 2015, and the Board has already established a process for receiving feedback. Hopefully, the decisions made in developing the evaluation rubrics will provide education stakeholders the information they need to know whether the LCFF is fulfilling the promise to improve education for the disadvantaged students who need those improvements the most.
— Jonathan Kaplan