COMMENTARY: District plans need more rigorous review by county leaders

Credit: Julie Leopo/EdSource

Right now, school district and charter school leaders, working with parents and the community, are starting to draft their Local Control and Accountability Plans. State law requires new plans every three years and annual updates to show how they plan to use and have used the funds they receive from the state under the Local Control Funding Formula.

The Covid-19 outbreak a year ago forced districts to move three-year planning to the back burner as district staff scrambled to keep delivering learning opportunities at home. Now planning is back on the front burner and soon will be in plain view of parents, voters, students and staff as the new Local Control and Accountability Plan is developed to show how districts will improve academic achievement, lower suspension rates and absenteeism and other areas of state concern.

This moment is a rare opportunity for district administrators to look with fresh eyes at how they deliver education and the quality of the results. It is also the time to give county offices of education more oversight authority.

The LCAPs reveal districts’ values. They determine where funds are invested, how much directly benefits students, how much benefits teachers and which programs live or die. These plans also reflect where district leaders think they are underperforming and how they will remedy these shortcomings.

No patient, however, should be his own physician. County offices of education serve as doctors to districts’ financial health. They have sign-off authority (and responsibility) for districts’ budgets and to their labor agreements. Why don’t they have a similar authority to reject plans that make poor assumptions about performance or target the wrong areas for improvement and send them back for rewriting before districts present them to their own school boards?

County offices do review each district’s plan, but review is constrained by law and policy to three simple questions: Did they answer all the questions on the state form? Can they afford to implement the plan? Is the plan spending money on English learners, low-income students and other high needs students as required by law?  

This is not a review. All too often, it is a charade.

COMMENTARY: District plans need more rigorous review by county leaders

Courtesy: Barbara Nemko,

Barbara Nemko, Napa County Office of Education

One educational leader who won’t play is Napa County Office of Education Superintendent Barbara Nemko. She and her deputy, Josh Schultz, have encouraged their staff to confer with district planning teams at the start of their planning process. Lucy Edwards, the Napa County Office of Education’s LCAP review chief, has invited district leaders to share their thinking before they draft their plans. Her diplomacy has built a climate of trust that makes better plans possible.

Superintendent Nemko, however, wants county offices to have more say. Rules governing the county office’s review reveal a mismatch of authority and responsibility, Nemko told me.

“Right now, county offices of education are only permitted to do a once-over lightly compliance review of their districts’ Local Control Accountability Plans. They are not allowed to dive into the content or results…. County offices of education have teeth when it comes to budget oversight, thanks to AB1200,” she said. “Why not give them the same oversight on the education side of the house? … Isn’t it time to put some serious oversight into how the money is being spent? And what results are being achieved?”

Nemko’s ideas are timely.

Her view is also consistent with a pre-pandemic report from the state Legislative Analyst’s Office, which urged the Legislature in January 2020 to direct the Department of Education, the California Collaborative for Educational Excellence and the county offices of education to develop a set of accountability plan review standards.

The next steps should include putting more substance into the review process, the report suggests: “Based upon a holistic review of the district using the new review standards, a [county office of education] could assign a qualitative rating to the LCAP — for example, positive, qualified or negative (borrowing terms the offices already use to review district budgets). A poor rating would trigger more county office of education support for the district. Such an approach would make COEs’ role in instructional oversight somewhat more analogous to their role in fiscal oversight.” (Read more about the Legislative Analyst’s Office recommendations here.)

Nemko and the state’s legislative analyst are not the only critics. Scholars Julia Koppich and Daniel Humphrey captured exasperation with the process in interviews with more than 80 superintendents in September 2018. (This blog post recaps the report.) Koppich and Humphrey distilled their criticism of the entire Local Control Funding Formula law, the biggest change in state funding of public education in 40 years, which shifted most spending decisions away from the state and under local control and away from the state into three areas: compliance thinking on the part of district leaders (indicating compliance with state laws and regulations without considering if it makes sense for the district), districts coming up with excessively complex plans or even unreadable plans.

For many districts, what precedes their county office review is simply pretending to plan.

Too many plans merely justify staffing decisions and curriculum adoptions made years ago. Identifying weak spots would be an admission of a mistaken judgment. Someone would be blamed. Programs might need trimming. People might lose their jobs. Planning requires the courage to be self-critical and have a tolerance for conflict. Both are in short supply.

After reading dozens of these plans, I’m astonished at the misuse of data, the mismeasurement of districts’ vital signs and sloppy reasoning. Why not give each plan the same attention afforded a high school student’s term paper and question flawed evidence and illogical thinking? If county offices of education had the authority to review the heart of districts’ plans — e.g., are the improvements aimed at the most deserving students? How will these changes lead to improvements? What evidence would indicate success or failure? — better plans should result.

Districts and county offices can do better. The Legislature can help by reforming the law that constrains county offices. Parents, school board trustees, teachers and staff should demand better plans from their districts, and tougher review of those plans by their county office of education. We should all expect clearer thinking anchored to evidence of higher quality than we are seeing now.


Steve Rees is founder of School Wise Press and leads its K-12 measures team.

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