federal program monitoring notification of findings · pdf filethe lea is required to resolve...

This is the official Notification of Findings (NOF) report of the review visit conducted by the California Department of Education(CDE). Because the methodology of the review involves sampling, it is not an assessment of all legal requirements. Nevertheless,the local educational agency (LEA) is responsible for operating its federal categorical programs in compliance with all applicablelaws and regulations.

The LEA is required to resolve each Federal Program Monitoring (FPM) finding within 45 calendar days which ends on 02/02/2015.When a FPM finding cannot be resolved within this 45 calendar day period, the LEA submits a resolution agreement request usingthe "Proposed Resolution of Findings" process via CAIS. Authorized LEA staff may request suggestions from CDE staff on theresolution of findings.

NOTE: Copies of this report were distributed to the LEA. This is a public report and must be made available upon request.(California Public Records Act, Government Code section 6250)

Program Reviewed Program Reviewer

Physical Education 2014–15 (PE) Michael Lee

Fiscal Monitoring 2014–15 (FM) Tami PiersonApril Woodcheke

Compensatory Education 2014–15 (CE) Larry BoeseTed Hawthorne

Career Technical Education 2014–15 (CTE) Geoff Belleau

Early Education and Support On-site 2014–15 (EES) Cindy GraysonSandy PatitucciAlice Trathen

Education Equity 2014-15 (EE) Gary Bell

Improving Teacher Quality 2014–15 (ITQ) Juan J. Sanchez

English Learner On-site 2014–15 (EL) William Vang

Before and After School Programs On-site 2014–15 (BASP) Joshua Brady

Uniform Complaint Procedures 2014–15 (UCP) Raquel CastellonShanine CoatsJean LeonardSally LewisBobby Roy

County: San Diego Review Dates: 12/08/2014 - 12/19/2014

FPM Region: Region 09

FPM Coordinator: Vikki Henton Telephone: 619-725-7093 E-mail: [email protected]

Regional Team Leader: Carmela Kelly Telephone: 916-319-0300 E-mail: [email protected]

Generated by CAIS on 12/19/2014, Findings of 34California Department of Education

Federal Program MonitoringNotification of Findings

County/District Code: 37683380000000 LEA Name: San Diego Unified

FOR OFFICIAL CDE USE ONLY:

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Brooklyn Child Center XGolden Hill Elementary X X X XClark Middle X X XParadise Hills Preschool XClay Elementary XCrawford High X X X X XFarb Middle XLincoln High XKearny SCT XValencia Park State Preschool

X

University City High XCol Salomon Child Ctr XMira Mesa High XLinda Vista Elementary X X X X XHorton Elementary X X X XMission Bay High X X X XCarver Elementary X X XEuclid State Preschool X

Sites and Programs Monitored




The means by which a finding is resolved is the responsibility of the LEA unless specified in law.Authorized LEA staff may request suggestions from CDE staff on the resolution of findings.

Findings by Program

Program Item Identifier

Item Title Item Findings Due Date

Before and After School Programs On-site 2014–15 (BASP)

No findings during this review.

Career Technical Education 2014–15 (CTE)

I-CTE 01 Advisory Committee

Status: Does Not Meet Requirements

Each LEA receiving Perkins IV funds must involve parents, students, academic and career technical education teachers, faculty, administrators, career guidance and academic counselors, representatives of business and industry, labor organizations, representatives of special populations, and other interested individuals in the development, implementation, and evaluation of CTE programs. The governing board of each school district participating in a career technical education program shall appoint a career technical education advisory committee to develop recommendations on the program and to provide liaison between the district and potential employers. The committee shall consist of one or more representatives of the general public knowledgeable about the disadvantaged, students, teachers, business, industry, school administration, and the field office of the Employment Development Department (EDD). Based on review of documentation and interview of district staff, the CTE Advisory Committee (CCTEAC in this LEA) appointed by the board does not meet requirements. Aside from a annual report to the board, the governing board does not utilize the CCTEAC to develop program recommendations or provide as a liaison between the district and potential employers. Finally, participation did not include students. Documentation must be uploaded into CAIS showing that the CTE Advisory Committee now includes all required members and includes contact information and sign in sheets. It should also show that the governing board engages the CTE Advisory Committee to develop recommendations and provide liaison between the district and potential employers.

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II–CTE 03

Inventory Status: Does Not Meet Requirements

The governing board of each school district shall establish and maintain a historical inventory, or an audit trace inventory system, or any other inventory system authorized by the State Board of Education, which shall contain the description, name, identification numbers, and original cost of all items of equipment acquired by it whose current market value exceeds five hundred dollars ($500) per item, the date of the acquisition, the location of use, and the time and mode of disposal. A reasonable estimate of the original cost may be used if the actual original cost is unknown. This inventory must be conducted at least every two years. A review of documentation posted in CAIS and interviews of staff as well as observations on site showed that the inventory system does not include required elements of specific location of all items, the current condition of the item as well as a way to document bi-annual inventory in the centralized system. Finally, not all items on the inventory list were located in qualified CTE programs, specifically at the middle school level. The LEA must upload into CAIS historical inventory documents for all items purchased with Perkins funds. This documentation must include all required elements. Additional review onsite will be required to verify inventory.

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III-CTE 04

Perkins Funds Support CTE Programs


Funds made available under Carl D. Perkins Act, Title 1, Part C, must be used to support and improve career technical education programs that provide students with strong experience in and understanding of all aspects of an industry. Further they must follow federal guidelines that affect allowability of costs. To be allowable under Federal awards, cost must be (1) necessary and reasonable for proper and efficient performance and administration of the grant award; (2) be allocable to Federal awards under the provisions of 2 CFR part 225; (3) be authorized or not prohibited under State or local laws or regulations; and (4) conform to any limitations or exclusions set forth in OMB cost principles or other governing regulations as to types or amounts of cost items. A review of provided documentation and interviews determined that not all charges attributed to Perkins were for programs that met state and federal regulations. Specifically, middle school programs that are not integral to the high school programs or taught by CTE qualified teachers. Further review of a sampling of expenditure found that not all expenditures were for qualified programs. Finally, there were programs that do not sufficiently provide students with a strong experience in and understanding of all aspects of industry within the pathways. The LEA must provide evidence that funds expended were used for qualified CTE programs. The LEA must work with the CDE consultant to do a complete review of the 13/14 expenditures to verify allocability of costs associated with Perkins and If documentation cannot be provided, all unallocable / unqualified expenditures will need to be remitted to the CDE. The LEA must upload documentation to CAIS documenting the allowability of costs. Finally the LEA must upload to CAIS documentation to show that all CTE programs provide students with a strong experience of all aspects of industry.

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III-CTE 06

Administrative Costs


The Act requires that each LEA receiving Carl D. Perkins Act, Title 1, Part C, funds shall not use more than five percent of the funds for administrative costs associated with the administration of the activities assisted (20 U.S.C. § 2355 (d)). A review of fiscal records indicated that the LEA charged an excess of the 5 percent in the amount of $300,659. There was 4.8 FTE of district staff costs reviewed and 1.202 FTE was allowable, allocable or fell within the 5 percent allowed by the Act. The LEA must provide evidence of reimbursement to the CDE of the excess of the 5 percent by uploading documentation of the payment. The LEA must work with their CDE Consultant to confirm the amount relating to allocable FTE for district staff and CDE Analyst to be billed in this amount.

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IV-CTE 08

Indicators of Performance


The Act requires that the LEA makes the annual report available to the public through a variety of formats, including electronically through the Internet. Further, the LEA must use annual evaluation results, including achieved core indicators performance levels, to determine needed program improvements, modifications, and professional development activities for staff. Review of documentation provided and interview with staff and chair of CTE advisory committee could not verify where the Indicators of Performance were made available to the public or how they were used for program improvement. The LEA must upload to CAIS updated procedures for review of data submitted including but not limited to professional development/technical assistance for relevant staff and identify process of sharing information with the public for program evaluation, needed improvements, modifications and needed PD. The LEA must work with the CDE to ensure that accurate and reliable CTE data is reported to the CDE as defined by the State Plan for Career Technical Education.

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VII-CTE 09

High Quality CTE Program


The CA State Plan for CTE requires each LEA receiving funds under Perkins include a sequence of courses in all CTE programs that are staffed by qualified CTE teachers, meaning teachers who 1) possess a standard secondary, single subject, or designated subject credential which authorizes the teaching of the CTE course(s) to which assigned, and 2) can document employment experience, outside of education, in the career pathway addressed by the program or other evidence of equivalent proficiency. They must focus on current or emerging high skill, high wage, or high demand occupations, CTE programs must integrate the development of CTE and academic skills in order to prepare students for immediate employment upon graduation and for further education or training. And they must provide for the development of student leadership skills through an established career technical student organization (CTSO) or an alternate strategy that incorporates this instruction in all of the courses that make up the sequence. A review of documentation posted in CAIS and interviews of site and district staff showed that not all CCTE teachers had appropriate credential (at the middle school level) and documented industry experience. The LEA is in the process of updating the curriculum maps and outlines. The Health Science Academy has participated in the CAL-Hosa CTSO. The LEA must upload to CAIS documentation showing that CTE programs are taught by qualified CTE teachers as outlined above, work with their CTE teachers to document relevant/recent industry experience, and updated curriculum maps and outlines showing integration of student leadership skills and "all aspects of industry".

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Compensatory Education 2014–15 (CE)

I-CE 02 School Parent Involvement Policy


Federal law requires that, with approval from the local governing board, each Title I school shall jointly develop with, and distribute to, parents of Title I students a written parental involvement policy, agreed upon by such parents and updated periodically to meet the changing needs of parents and the school; and that describes the means for carrying out the federal requirements for: • Policy Involvement (2.2, a through f) • Shared Responsibilities for High Student Academic Achievement (2.3, a through c, pertaining to the school-parent compact) • Building Capacity for Involvement (2.4, a through f) • Accessibility (2.5) The Title I Parent Involvement Policies for all of the eight schools reviewed are quite similar and do not clearly or adequately address the following elements of this CE item: 2.2 (e) and (f); 4.4 (a), (c), (d), and (f); and 2.5. Some of the bulleted items in each policy do not clearly align with the any of these required elements, and some elements that are partially addressed need to be more clearly identified and stated. The district must work with all of its Title I schools to assist and direct them in revising these policies to clearly identify and adequately address all sub-item elements using an outline or template such as the one available on the California Department of Education Website or a similar template that clearly outlines 2.2 (a) through (f), 2.4 (a) through (f), and 2.5. When the Parent Involvement Policy of each of the eight Title I schools included in this CE review have been revised with parent input to address all required elements of this item and approved by the SSC, they must be uploaded to this item in CAIS.

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II-CE 04 Monitoring the LEA Plan


Federal law requires an LEA Plan for LEAs receiving ESEA Title I, Part A funds and also requires an LEA operating Title I programs to implement, monitor, and review the effectiveness of efforts described in the approved LEA Plan to help low-achieving children meet challenging achievement academic standards. The district's LEA Plan is now aligned to the goals in its LCAP, required for LEA receiving LCFF funds, but it does not describe to LEA's Title I program or indicate how Title I, Part A funds will be used to support implementation of strategies and actions to help low-achieving children meet challenging achievement academic standards. The district must develop or revise its current LEA Plan as needed and upload to this item an LEA Plan that clearly describes its Title I program and indicates how Title I, Part A funds will be used to support implementation of strategies and actions to help low-achieving children meet challenging achievement academic standards.

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II-CE 07 School Site Council Composition


State law requires that the School Site Council (SSC) is composed of the following members selected by peers: (a) In elementary schools, half the members shall consist of the principal, classroom teachers, and other school personnel. Classroom teachers shall make up a majority of this group. The remaining half of the members shall consist of parents or other community members selected by parents. (b) In secondary schools, half of the members shall consist of the principal, classroom teachers, and other school personnel. Classroom teachers shall make up a majority of this group. The remaining half of the members shall consist of equal numbers of students selected by students, and parents or other community members selected by parents. All of the eight Title I schools included in this review met the relevant elementary or second SSC composition requirements as listed above. However, although some schools were able to provide evidence of peer selection for some SSC member groups (usually parents), evidence of peer selection of SSC classroom teacher, other personnel, and parent and community members, and--at high schools--SSC student members was almost entirely missing for most of the schools. In addition, SSC minutes and other documents uploaded to this item, as well as interviews with SSC members at each site, indicated that in many instances--especially in secondary schools--classroom teachers, other staff, and even parents volunteered or were recruited by the principal to fill open positions on the SSC without any vote by peers at meetings or by ballot to elect or confirm those who volunteered to be on the SSC. In at least one case, parent members were recruited for the SSC without the opportunity being given to all parents to self-nominate or nominate others to serve on the SSC. In addition, some sites are not clear that the SSC classroom teacher group does not included all certificated staff such as counselors and that the SSC other personnel group includes non-classroom certificated and administrators other than the principal as well as classified staff. The district must work with the eight schools reviewed and all of it other Title I schools to provide guidance and hold them accountable for putting adequate peer selection processes in place for all relevant SSC member groups, including opportunities for all peer group members to nominate themselves or others to represent the group on the SSC and opportunities for all peer group members to select

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or elect their SSC representatives from those nominated even when the number of nominees is equal to the number of openings for the group on the SSC. The district must also provide guidance and ensure that adequate documentation of the peer selection process is in place for all SSC members, including classroom teachers, other personnel, parents and community members and--for schools using the secondary SSC model--students. For those cases in each of the eight schools where any SSC members were not elected or confirmed by their peers, schools must hold elections which may include opportunities for new nominations but at the very least must involve a confirmation vote of current SSC members. The district must upload a document containing guidelines that it will provide to every school with an SSC on how to implement and document adequate peer selection processes for all member groups that make up the SSC; and complete documentation of peer selection for each SSC member group at each of eight school reviewed must be uploaded to this item in CAIS.








II-CE 08 SSC Approves SPSA


State and federal law require that the School Site Council (SSC) at a Title I school annually develop, review, update, and approve a Single Plan for Student Achievement that addresses the relevant Title I requirements of this item and that contains: (a) An analysis of academic performance data to determine students’ needs. (b) School goals to meet the identified academic needs of students. (c) Activities to reach school goals that improve the academic performance of students. (d) Expenditures of funds allocated to the school through the CARS. (e) The means of annually evaluating the progress of programs toward accomplishing the goals, including determining whether the needs of all children have been met by the strategies used, particularly the needs of low-achieving students and those at risk of not meeting state academic content standards. The SPSA template that the district required its Title I schools to use in 2013-14 provided a single row under each goal to describe actions and expenditures for meeting the goal but did not have a column to identify the action or strategies to be implemented with the various expenditures reported under each goal. Most of the schools included in this review did not complete actions statements for many SPSA goals or only provided a brief statement that did not adequately describe actions to be implemented by expenditures in the plan, as required by 08 (c), In many cases it was not possible to determine if expenditures were allowable uses of Title I funds that supplemented and did not supplant unrestricted State and local funds, and several supplanting issues were identified based on further evidence provided on site at the schools reviewed (as described in comments posted to CE 18).

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Because it is too far into the 2014-15 year to have each school make major revisions to the 2013-14 SPSA and the district has indicated that it is revising the SPSA template for 2014-15 and putting the annual review, updating, and approval of the SPSA on a new cycle, the district must upload a 2014-15 SPSA for each of the schools that clearly describes actions and strategies aligned to each Title I expenditure included in the plan after it has been approved by the SSC and local governing board. Any supplanting issues identified for the use of 2014-15 Title I school allocations at any of the sites (see CE 18) must be resolved in the SPSAs to be uploaded to this item.








III-CE 17 LEA Disburses Funds Consistent with CARS


Federal and state law require that the LEA disburse Title I, Part A and EIA/SCE funds in accordance with the approved Consolidated Application Reporting System (CARS) and expend Title I, Part A funds reserved in its CARS for the stated and approved purpose of the reservations (17.2). In addition, the LEA must have written assurances that it ensures comparability of services from state and local funds across district schools that address the following items: (1) LEA salary schedule; (2) equivalence among schools in teachers, administrators, and other staff; and (3) equivalence among schools in the provision of curriculum materials and instructional supplies. Adequate evidence was not provided that some of the Title I reservations in the district's 2013-14 CARS were used for their stated and approved purposes, including the funds reserved for PI LEA Professional Development ($3,875,962) and Homeless Services ($743,781). In addition, the district does not have a local board-adopted written policy or procedure providing assurances that comparability of services across all of its schools is ensured in the areas identified above. In addition to uploading an expenditure report for the PI LEA PD reservation to CE 21, the district must upload an expenditure report and a narrative description for the Homeless Services reservation to this item in CAIS. The district must also develop and upload a local board-adopted policy or administrative procedure document containing written assurances of comparability of services to all district schools from state and local funds in the areas referred to above.

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III-CE 18 Supplement Not Supplant with CE $


Federal law requires that the LEA must use Title I, Part A funds for their intended purposes only to supplement, and not supplant, state and local funds Based on documents provided on site, supplanting issues were found at San Diego Science & Technology High and at Mission Bay High but have been partially addressed with Position Allocation Requests submitted to the district to reverse Title I funds from teacher assignments that were not allowable Title I expenditures to teacher assignments which were allowable Title I expenditures. Supplanting also occurred at Horton Elementary because Title I funds approved in its 2014-15 budget for the Resource (Push-in/Pull-out) Teacher to continue the work of this position conducted in the 2013-14 year were, instead, approved by the site and district to pay for a regular classroom teacher position. Although the district has already reversed funding for the regular classroom teacher paid from Title I for the first trimester and restored these funds to the school's budget (a total of $27,608.54), as evidenced in documents uploaded to this item, the Horton SSC still needs to decide how to use the Title I funds that are now available in line items for this position for the remainder of the year. In addition, probable supplanting issues are indicated in some of the job descriptions and duty statements for staff positions in various district office departments that were uploaded to this item very late in the FPM review and which will take more time to for the CE reviewer to analyze and ask for further clarification or documentation from the district where needed, such as for staff funded 100% from Title I in Monitoring and Accountability Reporting (Dept. 5491) who are involved in WASC study work and monitoring of other federal and state programs in addition to Title I and for seven Resource Teachers paid 100% from Title I in Educational Technology (Dept. 5434) that appear to be providing Common Core and general educational technology services that should be paid from state and local funds, including the district's Common Core Implementation grant, to both Title I and non-Title I schools on a comparable basis. To address the clear supplanting issues referred to above, the district must work with school sites to take the following steps: Process the Position Allocation Requests already submitted for Sci. & Tech. High and Mission Bay High, as evidenced by reversal of funds in ledger documents, and work with the SSC at Horton Elementary to restore the Resource Teacher with Title I funds and/or find other effective actions and strategies that are allowable Title I expenditures to address the academic needs of at-risk students and document this in the 2014-15 SPSA yet to be updated and approved by the SSC and local governing board (see CE 08). The district must also work with the CE reviewer to address

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probable supplanting issues with district staff paid all or in part from Title I by providing further clarification and documentation needed to determine which issues are and are not supplanting and to resolve those that are.








III-CE 19 LEA Administrative Charges; Time Accounting


Federal and state regulations and standard accounting procedures require that each employee paid in part from a single cost objective or resource code and in part from other revenue, or an employee paid from multiple cost objectives or resource codes, must complete a Personnel Activity Report (PAR) for each pay period. Time accounting documents uploaded by the district for multi-funded staff paid in part with Title I, Part A funds and in part from other federal, state or local funds consists primarily of semiannual certification forms suitable for staff paid entire from one funding source or cost objective. Based on duty statements and job descriptions uploaded for Title I-funded staff at the eight reviewed school sites and for some of the district office departments indicate that some of these staff are on fixed schedules (such as classroom teachers) that would permit the use of a short-form PAR for monthly reporting or semiannual reporting under the federally-approved Substitute System for Time Reporting that would still require a different time accounting form than the batch semiannual certifications provided. In addition, many of the job descriptions and duty statements uploaded indicate variable duties and assignments for many positions that are not on fixed, predetermined schedules, for which a more detailed monthly PAR showing hours worked each day under each funding source is needed. At Clark Middle School the staff paid all or in part with Title I, Part A funds did not coincide with the class teaching assignments on the Master Schedule that qualified for Title I funding as supplemental intervention and support classes. The district must develop and utilize a more adequate short-form PAR for multi-funded staff paid in part with Title I, Part A funds who are on fixed, predetermined schedules which can be confirmed with work-assignment documents; and it must develop and utilize a more detailed monthly PAR for multi-funded staff paid in part with Title I, Part A funds who have variable work assignments and duties on a day-to-day, week-to-week and/or month-to-month basis. When the district has developed short-form and detailed PAR forms or templates for multi-funded staff on fixed and variable work schedules, it must upload them to this item in CAIS for review by the CE reviewer. It must then utilize the appropriate PAR for each staff person at the eight school sites and the district office would is multi-funded in part from Title I, Part A for at least one month or pay period and signed by the staff person and supervisor after the end of the pay period and upload the PARs to this item in CAIS. For regular classroom teachers at Clark MS and other Title I schools in the district who are paid all or in part from Title I funds, their class assignments should support the use of Title I funds for supplemental-intervention or extended-time classes for students needing extra support

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in the subject areas to which they are assigned.








III-CE 21 LEA in PI: 10% Reservation for Prof. Dev.


Federal law requires that an LEA in PI must reserve and spend not less than 10 percent of Title I, Part A funds for professional development (PD) for instructional staff. Although documents pertaining to PD provided by the district were uploaded to this item, the district has not provided an expenditure report as evidence that it has spent the 10% of its Title I funds reserved in CARS to provide PD to its instructional staff. The district must upload a summary expenditure report that breaks out the expenditures by object code for the amount reserved in its 2013-14 CARS for the Title I, Part A Required Reservation for PI LEA PD.

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Early Education and Support On-site 2014–15 (EES)

II-EES 02

Family Eligibility Requirements


The LEA is responsible for certifying and maintaining family eligibility documentation that is complete and meets requirements for enrolling families in the program. A review of selected certified family files revealed errors in the eligibility process that was used to enroll families. Errors included incomplete applications for services, inadequate family size documentation, miscalculation of income and not updating the documentation as required. The LEA must upload the corrective action plan for the development and implementation of a system to enroll families that will ensure all required documentation is collected for certifying and updating family eligibility files.

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II-EES 03

Child Need Requirement Verification


The LEA is responsible for collecting and maintaining need for service documentation for enrolling families in the full day contracts. A review of the family eligibility files revealed that the required documents to determine the need for service was inadequate, incomplete or needed to be updated. The LEA must upload the corrective action plan for the development and implementation of a system to collect and update the need for services as required for full day certifications.

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II-EES 04

Recording and Reporting Attendance


The LEA is required to adopt policies and procedures for recording and reporting attendance that are consistent with legal requirements. The attendance policies adopted by the LEA do not meet legal requirements. Documentation reviewed to determine whether child absences are excused or unexcused does not meet legal requirements. Absences for in the Best Interest of the child were lacking a tracking system to ensure not more than 10 days are granted per fiscal year. The absence records reviewed did not always contain the signature of the parent, or if verification is made by phone, the signature of the contractor's authorized representative. In addition, the attendance sign-in/sign-out records do not always contain the full signature of parents or legal guardian. The LEA must upload the new adopted attendance policy and the system that will be used to verify the tracking and documenting of excused and unexcused absences. The plan will include maintaining required signatures for absent days, tracking the 10 days of absences due to best interest days and that the attendance sign-in/sign-out records contain the full signature of parents.

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II-EES 05

Correct Fee Assessed


The LEA is responsible for adopting policies for assessing and collecting family fees for families enrolled in the full-day contracts in accordance with the current Family Fee Schedule issued by the California Department of Education. The LEA’s adopted policy is in conflict with legal requirements for late fees. The district policy does not allow children to attend if the family fees is not paid by the fourth day after the fee is due. The LEA must upload new family fee policies that are consistent with legal requirements.

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II-EES 06

Inventory Records Status: Does Not Meet Requirements

The LEA must maintains an inventory record for each piece of equipment with an acquisition cost of $500 or more per unit that is purchased with state and/or federal funds. The record describes the acquisition by: (a) Type/description, (b) Model/name, (c) Serial number, (d) Funding source, (e) acquisition date, (f) Cost, (g) Location, (h) Current condition, (i) Transfer, replacement or disposition of obsolete or unusable equipment and that the LEA has conducted a physical check of the inventory of equipment within the past two years and has reconciled the result with inventory records. A review of the inventory record determined that the inventory document was missing the following items: (d) funding source and (h) current condition of the equipment. In addition there was no evidence of a physical check of the equipment completed within the last two years. The LEA must develop and upload an inventory record for each piece of equipment with an acquisition cost of $500 or more per unit that is purchased with state and/or federal funds containing items (a-i), and that the LEA has conducted a physical check of the inventory has been conducted and the plan to reconciled the equipment every two years.

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IV-EES 08

Desired Results Profile and Data


The LEA is responsible for maintaining the Desired Results Developmental Profile-2010 (DRDP-2010) , and uses the information to plan and conduct age and developmentally appropriate activities. Based on a sampling of completed DRDP-2010, there was inadequate documentation to determine if the results were used to plan classroom activities. The LEA must upload the corrective action plan for the development and implementation of a system to collect data and use the information from individual children's DRDPs in planning classroom activities.

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IV-EES 10

Site Licensure Status: Does Not Meet Requirements

Each site operated by the LEA is required to maintain a current license issued by Community Care Licensing. While each site is licensed, there have been numerous Type A violations for health and safety issued by Community Care Licensing. The LEA must upload a corrective action plan for monitoring and ensuring the health and safety of all children that meet requirements.

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VII-EES 18

Environment Rating Scale


Each classroom shall achieve a subscale average of 5.0 on each subscale of the environment rating scale. Six classrooms were observed using a modified environment rating scale. Two of the sites did not achieve an average of at least a 5.0 on each subscale. The LEA must upload a corrective action plan describing how each subscale average will achieve at least a 5.0.

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Education Equity 2014-15 (EE)

II-EE 01 Administrative Requirements


The LEA must adopt a policy that prohibits discrimination, harassment, intimidation, and bullying based on actual or perceived ancestry, age, color, disability, gender, gender identity, gender expression, nationality, race or ethnicity, religion, sex, sexual orientation or association with a person or a group with one or more of these actual or perceived characteristics. Additionally, the non-discrimination policy shall include the following: a) a statement that it applies to all acts related to school activity or school attendance within a school under the jurisdiction of the superintendent of the school district. b) Requires that school personnel take immediate steps to intervene when it is safe to do so and when he or she witnesses an act of discrimination, harassment, intimidation, or bullying. Based on interviews with district staff and a review of provided documents, the LEA does not meet these requirements because the LEA’s non-discrimination board policy does not address discrimination, harassment, intimidation, and bullying and does not include above mentioned sub items (a) and (b). Additionally, the provided student handbooks do not include a valid non-discrimination statement and the complete uniform complaint process geared toward students. Furthermore, the Facts for Parents Annual Update handbook’s complaint process does not include a component which ensures that complainant’s identity remains confidential. Moreover, the LEA must provide evidence of the notification and dissemination of the revised notices to all required parties. Additionally, The LEA must upload a confirmation statement signed by the district superintendent certifying that all schools have posted the necessary nondiscrimination policies in schools and offices, including staff lounges and student government meeting rooms. (On district letterhead) The LEA must provide evidence by uploading into CAIS, an approved non-discrimination board policy that prohibits discrimination, harassment, intimidation, and bullying based on actual or perceived ancestry, age, color, disability, gender, gender identity, gender expression, nationality, race or ethnicity, religion, sex, sexual orientation or association with a person or a group with one or more of these actual or perceived characteristics and the policy must contain sub items (a) and (b). Additionally, provide student handbooks that include a valid non-discrimination statement and the complete uniform complaint process geared toward students. Furthermore, the Facts for Parents Annual Update handbook’s complaint process must include a component which ensures that complainant’s identity remains confidential. Moreover, the LEA must provide evidence of the

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notification and dissemination of the revised notices to all required parties (Including postings on District and School Websites). Additionally, The LEA must upload a confirmation statement signed by the district superintendent certifying that all schools have posted the necessary nondiscrimination policies in schools and offices, including staff lounges and student government meeting rooms. (On district letterhead)








II-EE 03 Governance Rule Status: Does Not Meet Requirements

The LEA must ensure that no rule is applied concerning a student’s actual or potential parental, family, or marital status that treats students differently on the basis of sex, and (3.1) does not exclude or deny any student from any educational program or activity solely on the basis of pregnancy, childbirth, false pregnancy, termination of pregnancy, or recovery therefrom. Additionally, (3.2) pregnant students and parenting male or female students are not excluded from participation in their regular school programs or required to participate in pregnant-student programs or alternative educational programs. Furthermore, (3.3) pregnant/parenting students who voluntarily participate in alternative programs are given educational programs, activities, and courses equal to the regular program. Moreover, (3.4) the LEA treats pregnancy, childbirth, false pregnancy, termination of pregnancy, and recovery therefrom in the same manner and under the same policies as any other temporary disability. Based on interviews with district staff and a review of provided documents, the LEA does not meet these requirements because the LEA’s board policy/procedure related to student’s actual or potential parental, family, or marital status and which prohibits the treatment of students differently on the basis of sex does not include parenting students in regard to sub items (3.2 and 3.3). Additionally, the LEA’s board policy/procedure does not include sub item (3.4). The LEA must provide evidence by uploading into CAIS, an approved board policy/procedure that prohibits discrimination based on student’s actual or potential parental, family, or marital status and which prohibits the treatment of students differently on the basis of sex which include parenting students in regard to sub items (3.2 and 3.3). Additionally, the LEA’s board policy/procedure must include sub item (3.4).

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II-EE 04 Sex Equity Status: Does Not Meet Requirements

The LEA must adopt a policy that prohibits sexual harassment as a form of sexual discrimination and provides notification of available remedies. Based on interviews with district staff and a review of provided documents, the LEA does not meet these requirements because the LEA’s board policies prohibiting sexual harassment do not include updated language and available remedies. The LEA must provide evidence by uploading into CAIS, approved board policies prohibiting sexual harassment which contain updated language and available remedies and must be disseminated to parents, students, employees, the general public and all required parties (Including postings on District and School Websites).

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VII-EE 06

Opportunity and Equal Educational Access


The LEA must ensure that programs, activities, and student clubs are available to all persons without regard to actual or perceived ancestry, age, color, disability, gender, gender identity, gender expression, nationality, race, ethnicity, religion, sex, sexual orientation, or association with a person or a group with one or more of these actual or perceived characteristics. Based on interviews with district staff and a review of provided documents, the LEA does not meet these requirements because the LEA’s board policy/procedure related to student programs, activities, and student clubs does not include all the newly adopted language consistent with “Education Code 200” pertaining to additional protected groups. The LEA must provide evidence by uploading into CAIS, an approved board policy/procedure related to student programs, activities, and student clubs which includes all the newly adopted language consistent with “Education Code 200” pertaining to additional protected groups.

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English Learner On-site 2014–15 (EL)

II-EL 08 Implementation, Monitoring & Revision of LEA Plans


A LEA operating Title III programs must annually update, implement and monitor Goal 2 of the approved LEA Plan. The plan must contain the minimum required components of 8.1(a) to 8.1(g). LEAs and consortia that have failed to make progress towards meeting the AMAO target(s) for two consecutive years and are thus identified as being in Title III Program Improvement (PI) status shall develop an improvement plan (the Improvement Plan Addendum for Goal 2 of the LEA Plan) no later than three months after notification of status. LEAs and consortia that have failed to meet the AMAO target(s) for four consecutive years shall modify their curriculum, program, and method of instruction (revised Improvement Plan Addendum for Goal 2 of the LEA Plan). A review of documentation and interviews with district staff revealed that the current LEA plan does not meet the legal requirements of EL 8. The LEA has not annually updated, implemented, and monitored the LEA Plan Goal 2 since the end of 2012 school year. The estimated costs were not stated and tied to the actions and activities described in the plan. The LEA must upload the new board-approved 2014-15 Goal 2 of the LEA Plan containing all sub-items 8.1 (a) to 8.1 (g) along with board meeting minutes, agendas, and fiscal records that reflect the amount of Title III fund allocated to LEA through CARS. The Goal 2 of the approved LEA Plan must describe how Title III funds are utilized to provide direct services to English learners and how services support students to meet academic proficiency, particularly the needs of low achieving English Learners, long-term English Learners, and newcomer students that are at risk of not meeting state academic content standards. The goals and activities must align with the intended purpose of the Title III funds. The estimated costs must be stated and tied to the goals and activities that address the academic needs of Title III students.

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Fiscal Monitoring 2014–15 (FM)

III-FM 01 Timekeeping Requirements


To support salaries and wages for employees that work on federal programs, the local educational agencies (LEAs) are required to maintain period certifications for employees working on a single activity or cost objective and personnel activity reports (PARs) or equivalent documentation for employees working on multiple activities or cost objectives. PARs must (1) reflect after-the-fact distribution of the activity of each employee; (2) account for the total activity which each employee is compensated; (3) be prepared at least monthly and must coincide with one or more pay period, and; (4) be signed by the employee. Budgeted percentages or estimates determined before the work is performed do not meet federal requirements. The LEA did not maintain PARs in accordance with federal requirements for employees that work on multiple activities or cost objectives. Specifically, the LEA's PARs did not contain all the required components, did not maintain records contemporaneously and did not consistently identify the employees' actual activities. The LEA is responsible for updating policy and procedures regarding maintaining PARs. In doing so, the LEA must work with CDE to develop reasonable timeline and plan for implementing these new procedures.

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Improving Teacher Quality 2014–15 (ITQ)








Physical Education 2014–15 (PE)

IV-PE 02 Evaluation - High School


The law requires high school students in grades 9-12, inclusive, to be evaluated on their progress in each of the eight required content areas. Based upon a review of documents, on-site observations, and district/site level administrator/teacher interviews, the LEA has not provided sufficient evidence that high school students in grades 9-12, inclusive, are being evaluated on their progress in the eight required content areas at Crawford High and San Diego Science and Technology. The LEA's course outlines for PE Course 1 (9th grade) and PE Course 2 (10th grade) together describe how students are evaluated in the eight required content areas. However, the physical education classes on the master schedules at Crawford High and San Diego Science and Technology do not reflect these course outlines; only "generic" physical education classes are offered that are comprised of students in grades 9-12. Additionally, students at Crawford High are not evaluated in gymnastics/tumbling or combatives. The LEA must provide evidence by uploading documentation in CAIS (e.g. revised master schedule, revised course outlines, etc.) showing that all students, unless otherwise exempted, at Crawford High and San Diego Science and Technology are being evaluated on their progress in each of the eight required content areas.

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VII-PE 06

Instruction - Middle and High School


The law requires all middle and high school students in grades 7-12, unless otherwise exempted, to receive physical education instruction for no less than 400 minutes each 10 school days. Based upon a review of documents, on-site observations, and district/site level administrator/teacher interviews, the LEA has not provided sufficient evidence that all students in grades 7-12, unless otherwise exempted, are receiving physical education instruction for a minimum of 400 minutes each 10 school days at Crawford High and San Diego Science and Technology. These high schools are on 4 x 4 block schedules, where students receive all of their physical education in one semester. Unless the block schedule is changed to an A/B block schedule format (where students take physical education every other day for the entire school year) or students are enrolled in physical education classes for the entire school year, a physical education block schedule waiver must be submitted to the California Department of Education. Crawford High also allows physical education credit for students in JROTC courses. Because neither JROTC teacher at Crawford High has a physical education credential/authorization, only less than half of the class can be taught as physical education (i.e. the primary focus of the class must be JROTC per the teachers' credential areas). As such, JROTC students are receiving less than 400 minutes of physical education instruction each 10 school days (380 minutes at most). Physical education credit is a decision of the LEA, but all students, unless otherwise exempted, must receive a minimum of 400 minutes of physical education instruction each 10 school days. The LEA must provide evidence by uploading documentation in CAIS (e.g. revised master schedule/description, CDE physical education block schedule waiver, etc.) that Crawford High and San Diego Science and Technology are requiring all students, unless otherwise exempted, to take at least 400 minutes of physical education each 10 school days. The LEA must also provide evidence by uploading documentation in CAIS (e.g. revised master schedule/description, physical education credentials/authorizations for JROTC teachers, additional physical education minutes, etc.) showing that all JROTC students at Crawford High are receiving a minimum of 400 minutes of physical education instruction each 10 school days.

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VII-PE 07

Teaching - High School


The law requires LEAs that maintain a high school to provide a course of study in physical education to students in grades 9-12, inclusive, with a developmentally appropriate sequence of instruction in the eight required content areas. Based upon a review of documents, on-site observations, and district/site level administrator/teacher interviews, the LEA has not provided sufficient evidence that high school students are being provided with a developmentally appropriate sequence of instruction in the eight required content areas at Crawford High and San Diego Science and Technology. The LEA's course outlines for PE Course 1 (9th grade) and PE Course 2 (10th grade) together describe a course of study that demonstrates a developmentally appropriate sequence of instruction in the eight required content areas. However, the physical education classes on the master schedules at Crawford High and San Diego Science and Technology do not reflect these course outlines; only "generic" physical education classes are offered that are comprised of students in grades 9-12. Additionally, students at Crawford High are not provided with instruction in gymnastics/tumbling or combatives. The LEA must provide evidence by uploading documentation in CAIS (e.g. revised master schedule, revised course outlines, revised PE Instructional Schedule for Crawford High, etc.) showing that students at Crawford High and San Diego Science and Technology are being provided with a developmentally appropriate sequence of instruction in each of the eight required content areas.

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VII-PE 08

Exempted Students I


The law requires school districts that maintain a high school and elect to exempt students from physical education for two years any time during grades 10-12, inclusive, to offer those exempted students a variety of elective physical education courses. Based upon a review of documents, on-site observations, and district/site level administrator/teacher interviews, the LEA has not provided sufficient evidence that a variety of elective physical education courses are being offered to students at Crawford High and San Diego Science and Technology. A "variety" is defined as a minimum of three elective physical education courses, of which High School Course Two may be applied if it is offered for elective credit. The LEA must provide evidence by uploading documentation in CAIS (e.g. revised master schedule/description, course syllabi, etc.) that Crawford High and San Diego Science and Technology are offering students a variety of elective physical education courses. Because San Diego Science and Technology is an academy school with an enrollment of under 500 students, a minimum of two elective physical education courses is sufficient to meet the requirements of this item.

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Uniform Complaint Procedures 2014–15 (UCP)






federal program monitoring notification of findings · pdf filethe lea is required to resolve...

Documents