Notification of Findings Federal Program Monitoring 2016...

California Department of EducationFederal Program Monitoring 2016-17

Notification of Findings

February 24, 2017

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 applicable laws and regulations.

Local Educational Agency: Los Angeles Unified (19647330000000)

Review Date(s): 02/06/2017 - 02/24/2017

Regional Team Leader(s): Carmela Kelly, 916-319-0300Malik Abdul-Khaliq, 916-319-0958

FPM Coordinator(s): Jose Jarquin, 213-241-7045Cathy Tomyoy, 213-241-7048

Program Reviewed Program Reviewer Total Findings

Adult Education (AE) Cliff Moss 0

Before and After School (BASP) Anissa Sonnenburg, Johannes Troost, Mignonne Pollard, Yvonne Evans

0

Compensatory Education (CE) Alan Frank, Ted Hawthorne, Oluwole Olukoya, Mary Beth Boyer

0

Career Technical Education (CTE) Linda Greer, Bryan Baker

1

Education Equity (EE) Murjani McTier 0

Early Education and Support (EES) Richard Miller 4

English Learner (EL) Deborah Busch, Suzie Dollesin

1

Fiscal Monitoring (FM) April Woodcheke, Paula Flores

3

Neglected or Delinquent (NorD) Karen Steinhaus 0

Physical Education (PE) Emily Oliva, Doug Jann 1

Uniform Complaint Procedures (UCP) Sally Lewis, Raquel Castellon, Bobby Dalton Roy, Shanine Coats, Jean Leonard, Kerri Ruzicka

0

Federal Program Monitoring 2016-17


Los Angeles Unified (19647330000000)

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.

California Department of Education 2/24/2017 9:31 AM Page 2 of 12

The LEA is required to resolve each Federal Program Monitoring (FPM) finding within 45 calendar days which ends on 04/10/2017. Corrective actions made to resolve findings must be implemented at all sites in the LEA and the new procedures must be used in the future.

When a FPM finding cannot be resolved within this 45 calendar day period, the LEA submits a resolution agreement request using the "Resolution Agreement" process via CMT. Authorized LEA staff may request suggestions from CDE staff on the resolution of findings.

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

Sites Reviewed Programs Reviewed

4th St EEC (6473) EES

Abraham Lincoln Senior High (19647331935121) CTE

Abram Friedman Occupational (19647331931278) CTE

Alta Loma Elementary (19647336015747) CE, BASP, EL, PE

Arminta St Child Ctr (6473) EES

Ascot Avenue Elementary (19647336015887) CE, BASP, EL, UCP

Bassett Street Elementary (19647336015960) CE, BASP, EL, PE

Belmont Senior High (19647331930924) CTE

Benjamin Franklin Senior High (19647331933043) CTE

Camellia Avenue Elementary (19647336016273) CE, BASP, EL, UCP

Canoga Park Child Ctr (6473) EES

Charles Drew Middle (19647336057962) CE, BASP, EL, PE

East Los Angeles Occupational (19647331930858)

CTE

Edward R. Roybal Learning Center (19647330117051)

CTE

Elizabeth Learning Center (19647336016885) CE, BASP, EL

Esteban Torres East LA Performing Arts Magnet (19647330122341)

CTE

Ford Boulevard Elementary (19647336017131) CE, BASP, EL, PE







Grover Cleveland Charter High (19647331931864)

CE, EL

Hooper Avenue Elementary (19647336017628) CE, BASP, EES, EL, UCP

Huntington Park Senior High (19647331934157) CTE

James A. Garfield Senior High (19647331933381) CTE

John H. Francis Polytechnic (19647331932987) CE, BASP, EL, PE

Linda Esperanza Marquez High A Huntington Park Institute of Applied Medicine (19647330126516)

CTE

Linda Esperanza Marquez High C School of Social Justice (19647330126532)

CTE

Magnolia Avenue Elementary (19647336017990) CE, BASP, EL, PE

Manual Arts Senior High (19647331935519) CTE, EL

Mary McLeod Bethune Middle (19647336058143) CE, BASP, EL, UCP

North Hollywood Senior High (19647331936350) CE, BASP, CTE, EL, UCP, PE

North Valley Occupational Center (19647331930841)

CTE

Richard E. Byrd Middle (19647336057905) CE, BASP, EL, UCP, PE

San Fernando Senior High (19647331937622) CTE

School of History and Dramatic Arts at Sonia Sotomayor Learning Academies (19647330124420)

CTE

Science, Technology, Engineering, Arts and Mathematics at Legacy High School Complex (19647330126540)

CTE

South East High (19647330109454) CE, BASP, EL, UCP

South Gate Middle (19647336058309) CE, BASP, EL, PE

South Gate Senior High (19647331938307) CTE

Stephen M. White Middle (19647336058366) CE, BASP, EL, UCP, PE

Sun Valley High (19647330119651) CTE

Sylmar Charter High (19647331938554) CTE







Theodore Roosevelt Senior High (19647331937424)

CTE

Thomas Jefferson Senior High (19647331934371) CTE

Van Nuys Senior High (19647331938968) CE, BASP, CTE, EL, UCP, PE

Verdugo Hills Senior High (19647331939107) CTE

Vista Middle (19647330106971) CE, BASP, EL

West Adams Preparatory High (19647330114850) CE, BASP, CTE, EL

West Valley Occupational Center (19647331932474)

CTE

West Vernon Avenue Elementary (19647336019889)

CE, BASP

Wilton Place Childrens Ctr (6473) EES

Wilton Place Elementary (19647336019988) CE, BASP, EL, PE

Woodrow Wilson Senior High (19647331939859) CTE

Monitor ing Results by Program

Adult Education

No program findings resulted from this monitoring review. No further action is required.

Before and After School


Compensatory Education


Career Technical Education

1. CTE 09: High Quality CTE Program






The State Board-approved CTE plan requires that each LEA receiving funds under Perkins include a sequence of courses in all CTE programs; provide students with coherent and rigorous content aligned with challenging academic standards and relevant technical knowledge and skills; and include the following planning, organizational, and instructional elements determined by the state to be critical to high quality CTE programs: (2008-12 CA CTE State Plan, Ch. 5(2), (3), (4)).

Be aligned with the State’s CTE Model Curriculum Standards and Framework, focusing on

current or emerging high skill, high wage, or high demand occupations, and include planned career awareness and exploration experiences.

Be a coherent sequence of CTE courses only, consisting of not less than two full-year CTE courses with a combined duration of not less than 300 hours; or a single, multiple hour course which provides sequential units of instruction and has a duration of not less than 300 hours, with objectives and content with a direct relationship to the occupation(s) or career targeted by the program.

LAUSD does not have course outlines aligned to the current version of the CTE Model Curriculum Standards for all CTE classes.

While LAUSD district office leadership has a coherent sequence of courses for all pathways defined, not all school sites are adhering to them. For example, Garfield High School CTE students starting their second or third year course of any of their five pathways are scheduled into the introductory course along with first-year CTE students.

LAUSD must update all of the course outlines for classes assisted with Perkins funds so they are aligned to the latest iteration of the CTE Model Curriculum standards (January 2013). Course outlines must give a chronological listing of activities, with each listed activity showing to which standard(s) it is aligned (Pathway-specific standards, Anchor Standards, and Standards for Career Ready Practice) that show 1) the pathway as a; whole covers all the CTE Model Curriculum Standards of the pathway, and 2) each course in the pathway spends at least half of its time on the CTE Model Curriculum Standards of the pathway.

LAUSD must remit Garfield High School’s Perkins spending for 2016-17 and 2015-16. LAUSD has begun the process of programming their student information system to enforce their sequencing of classes within pathways. To resume assisting Garfield High School’s CTE pathways with Perkins funds in 2017-18, LAUSD must submit Garfield’s 2016-17 master schedule reflecting a coherent sequence of courses, show any school-site brochures designed to recruit students into or promote their CTE programs to reflect this change, and show that their student information system has been programmed to limit the ability of school sites to schedule students out of sequence.

Education Equity


Early Education and Support






1. EES 03: Child Need Requirement Verification

With the exception of families enrolled in a part-day CSPP, families with children enrolled in a contract have met the need requirements. Certified hours of child care correspond to the need of the parent/caretaker, as documented by the contractor. For all contracts with a need for service requirement, the contractor verifies the need of each family or child within 30 days of a change in need status or at intervals not to exceed 12 months and at least once each contract period.

For the CCTR contract, based on a review of the family data files:

-in one of 34 CCTR files the family was certified Monday and Wednesday 8:30 a.m. to 4 p.m., Tuesday 10 a.m. to 5 p.m., Friday 11 a.m. to 7 p.m. Employment verification states hours may vary depending on the restaurants need. Agency certified incorrectly Monday through Friday 7:30 a.m. to 4:15 p.m., however parent has Thursdays off. Hours do not align with employment verification (5 CCR, Section 18074.1(a)).

The above findings contributed 4% to the Governance and Administration Unit’s assessed error

rate.

The combined error rate for Dimension II exceeds the error rate threshold of 10 percent. The LEA shall submit an Error Rate Reduction Plan. The plan shall address how the LEA will collect sufficient documentation to verify employment.

For the CSPP contract, based on a review of the family data files:

-in one of the 13 CSPP files the agency certified services Monday, Wednesday, and Friday 7:15 a.m. to 4 p.m., Tuesday and Thursday 7:15 a.m. to 1:45 p.m. Parent B attends school Tuesday and Thursday 8 a.m. to 12:45 p.m. Parent A works a variable schedule 50 to 60 hours per week. There is no need for full-time services Monday to Friday (5 CCR, Section 18074.1(a)); and

-in two of the 13 CSPP files one family self-employment income documentation was not present in the family file. Parent A provided a self-declaration but did not indicate the total countable for the month preceding certification or a statement of current estimated income, business records, or copies of documentation of all non-wage income. The second family file unable to determine need for parent B, however there is insufficient supporting documentation to determine the days and hours of care needed. The documentation that was used for parent B did not meet Title 5 requirements (5 CCR, Section 18084(a)(3)(A-C)); and

-in one of the 13 CSPP files the parent works Monday through Friday, 8 a.m. to 4 p.m. Employment verification found in file agency called and verified information. The documentation was not submitted until 10/10/16. Prior need of parent was based on training, and the semester duration was from 1/25/16 to 6/10/16. Parent did not have a need for services as of 6/10/16 until 10/10/16 employment documentation update (5 CCR, Section 18086(a)); and

-in one of the 13 CSPP files parent B was attending Adult School Maxine Waters Center, Monday to Friday 8 a.m. to 12:15 p.m. from 8/16/16 to 11/04/16. Additional document from the same training institution stated parent had a change, but this change was not reported in a






timely manner. Progress report pending. There is conflicting information on dates of the anticipated date of completion (5 CCR, 18087(c)).

The LEA shall submit a corrective action plan. The plan shall address how the LEA will collect sufficient documentation to verify employment, self-employment, and vocational training.

2. EES 04: Recording and Reporting Attendance

The program has adopted policies and procedures for recording and reporting attendance that are consistent with the certified hours of enrollment that are established for the parent/caretaker.

4.1 (CCTR, CSPP)

(a) Statutes and regulations on excused and unexcused absences; and

(b) Regulations regarding documentation of attendance


-in three of 34 CCTR files the full signature were not used on the sign-in/out sheet by the parent and/or other authorized adult (5 CCR, Section 18065(b)(1)); and

-in 10 of 34 CCTR files signatures were not used by the parent and/or other authorized adult for excused absences (5 CCR, Section 18066(a)(1-4)).

The above findings contributed 91% to the Governance and Administration Unit’s assessed

error rate.

The combined error rate for Dimension II exceeds the error rate threshold of 10 percent. The LEA shall submit an Error Rate Reduction Plan. The plan shall address how the LEA will ensure attendance is reimbursed for days that are actually used or meet the daily sign-in/out requirements.


-in four of 13 CSPP files signatures were not used by the parent and/or other authorized adult for excused absences (5 CCR, Section 18066(a)(1-4); and

-in two of 13 CSPP files one file parent A works from 8 a.m. - 2 p.m. Monday to Friday, per employer verification. Parent B is self-employed works from 10 a.m. - 5 p.m. and submitted his income tax forms along with supporting documentation. Agency did not certify correct hours of care dad does not have a need until 10 a.m. children are being dropped off at 8 a.m. and picked up about 3 p.m. by dad who is supposed to be working until 5:00 pm. Agency certified full-time care when three quarters time should have been certified. The second file hours of usage 8:30 a.m. to 3:30 p.m. were different than contract hours 6:30 a.m. - 4:00 p.m. Agency reimbursed 21 days at full-time care reviewer determined should have reimbursed 18 days at three-quarters time and 3 days at full-time (5 CCR, Section 18078(t).






The LEA shall submit a corrective action plan. The plan shall address how the LEA will ensure that attendance is reimbursed for days that are actually used or meet the daily sign-in/out requirements.

3. EES 05: Correct Fee Assessed

Families with children enrolled are assessed the correct fee according to the current Family Fee Schedule issued by the California Department of Education with the exception of families certified in a part-day CSPP program.


-in one of 34 CCTR files Application for Services was not updated noting parent’s hours full-time

plus to full-time (5 CCR, Section 18078(t)); and

-in one of 34 CCTR files were miscalculated based on the frequency of pay stubs provided by parent (5 CCR, Section 18096(a)); and

-in three of 34 CCTR files the contractor miscalculated income resulting in incorrectly assessed determination of family fees (5 CCR, Section 181091(a)(1)).

The above findings contributed 6% to the Governance and Administration Unit’s assessed error

rate.

The combined error rate for Dimension II exceeds the error rate threshold of 10 percent. The LEA shall submit an Error Rate Reduction Plan. The plan shall address how the LEA will ensure correct family fee is assessed based on verified total countable income and family size.


-in one of 13 CSPP files the income was assessed correctly, however family size was not documented correctly. There is no birth record of the second child counted in the family size. Family should have had a family fee assessed (5 CCR, Section 181091(a)(1)).

4. EES 18: Environment Rating Scale

Center based programs are required to complete an environment rating scale for the appropriate age group and setting and achieve a minimum average score of 5 or “Good” on each sub-scale.

For the CSPP contract, the environment rating scale scores assessed by the reviewer at the Canoga Park, 4th Street, and Arminta sites included a sub-scale (Personal Care Routines) that did not achieve a sub-scale score of 5 or "Good".

For the CSPP contract, the environment rating scale scores assessed by the reviewer at the Canoga Park site included a sub-scale (Space and Furnishings) that did not achieve a sub-






scale score of 5 or "Good".

The contractor shall submit corrective actions or a corrective action plan to achieve a sub-scale score of 5 or "Good" on all sub-scales on the Early Childhood Environment Rating Scale at the Canoga Park, 4th Street, and Arminta sites.

English Learner

1. EL 15: Teacher EL Authorization

Teachers assigned to provide English language development and instruction in subject matter courses for English learners must be appropriately authorized.

A review of the teacher authorizations provided by the LEA revealed that Los Angeles Unified School District employs 94 teachers who do not hold the proper EL authorizations. While 36 reportedly have no ELs in their classes, the remaining 58 are reported to have ELs in their classes.

The LEA must upload evidence (e.g., CTC permits/authorizations) that the misassigned teachers and any other teachers who may be assigned English learners have the proper EL authorizations for all types of instruction, regardless of the subject and the number of English learners in the class. For any teachers listed as "resolved - removed," the LEA must upload explanations of how the issue was resolved (i.e., what happened to the teacher or ELs in those classes). During the period that the teachers are misassigned, placement of an EL authorized teacher in all courses assigned to the identified teachers, either through side-by-side instruction or replacement, is highly recommended until the appropriate CTC permits have been acquired.

Fiscal Monitoring

1. FM 01: Timekeeping Requirements

To support salaries and wages for employees that work on federal programs, local educational agencies (LEAs) are required to maintain time accounting records that accurately reflect the work performed. These time accounting records must: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (2) be incorporated into the official records of the LEA; (3) reasonably reflect the total activity for which the employee is compensated by the LEA, not exceeding 100% of compensated activities; (4) encompass both federally assisted and all other activities compensated by the LEA on an integrated basis, but may include the use of subsidiary records as defined in the LEA’s written policy; (5) comply with the established accounting policies and practices of the LEA; and (6) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Budget estimates or percentages determined before






the services are performed alone do not qualify as support for charges to Federal awards.

The California Department of Education’s (CDE) review of a sample of employees who work on

federal programs found that the LEA did not maintain time accounting records in accordance with federal requirements. Specifically, based on CDE’s review, the LEA improperly charged $212,613 in salaries and benefits to the Title II program for two employees that improperly maintained semiannual certifications rather than detailed monthly time accounting records. Additionally, those three employees’ time accounting records reported that the employees only worked 50 percent of their time on the Title II program; however, the LEA charged 100 percent of their salaries and benefits to the Title II program. The LEA also improperly charged $240,823 in salaries and benefits to the Title II program for one employee whose time accounting records reported that the employee only worked 20 percent of her time on the Title II program; however the LEA charged 100 percent of their salary and benefits to the Title II program. Furthermore, the LEA failed to provide CDE the requested time accounting records to support an employee’s salary and benefits that were charged to the Title I, Part C program. As a result, the LEA failed to substantiate that $365 in salaries and benefits charged to the Title I, Part C program were properly supported and allowable. Moreover, the LEA‘s written time accounting policies and practices did not reflect the LEA’s current operations.

The LEA must reimburse $453,436 to the Title II program with unrestricted funds and upload documentation substantiating the reimbursement to the CDE Monitoring Tool (CMT). In addition, the LEA must update its time accounting policies and practices, and train staff on these procedures to ensure that the LEA maintains time accounting records in accordance with federal requirements. In order to ensure that the LEA is properly maintaining time accounting records, the LEA must upload the time accounting records for the sampled employees working on multiple activities or cost objectives for the months of March and April 2017. Furthermore, the LEA must upload into CMT the requested documentation to support the salaries and benefits charged to the Title I, Part C program. Pending the results of the review of the uploaded documentation or if the LEA fails to provide the requested documentation, the LEA may be required to reimburse $365 to the Title I, Part C with unrestricted funds to the federal program fund.

2. FM 02: Allowable Costs

LEAs are required to maintain documentation to substantiate that all costs charged to federal programs are reasonable, necessary, and allowable in accordance with applicable program requirements.

Based on CDE’s review of the LEA’s general ledger, supporting invoices and discussions with

LEA staff, CDE determined that the LEA improperly charged $5,400 to the Title IV program that was not reasonable or necessary to the administration of the programs. Specifically, based on the documentation provided, the LEA charged $5,400 to the Title IV program (resource code 4124) for advertising.

The LEA must reimburse $5,400 to the Title IV program with unrestricted funds and upload documentation to the CMT to support these reimbursements.






3. FM 03: Supplement, Not Supplant

LEAs are required to use Title I, Part A and C, Title II, Title III and Title IV funds only to supplement, not supplant, state and local funds.

Based on CDE’s review of the LEA’s time accounting records, the LEA improperly charged

$279,923 in salaries to the Title II program. Specifically, the documentation provided did not support that the employee’s activities were supplemental or allowable under the Title II program. In addition, the LEA failed to provide CDE the requested time accounting records supporting an employee’s salaries and wages that were charged to the Title IV program. As a result, the LEA failed to provide sufficient documentation to substantiate that the salaries and wages charged to the federal program was properly supported and allowable.

The LEA must reimburse $279,923 to the Title II program with unrestricted funds and upload documentation in CMT to support this reimbursement. In addition, the LEA must upload the requested Title IV time accounting documentation for review. Pending the results of the review of the uploaded documentation or if the LEA fails to provide the requested documentation, the LEA may be required to reimburse $256 to the Title IV with unrestricted funds.

Neglected or Delinquent


Physical Education

1. PE 06: Instruction - Middle and High School

The law requires middle school and high school students (grades 7-12) to receive physical education instruction for 400 minutes each 10 school days. Students in grades 7-8 who attend a K-8 elementary school in an elementary school receive physical education instruction at least 200 minutes every 10 school days.

Documentation and conversations with the district indicate that John H. Francis Polytechnic High School operates on a 4X4 Block Schedule and does not provide for daily physical education instruction to meet the 400 minutes of instruction every 10 school days. The district was not able to provide evidence that John H. Francis High School has a California State Board of Education (SBE) approved Waiver of Physical Education Requirements for Block Schedules.

The district must provide evidence that John H. Francis High School has a SBE approved Waiver of Physical Education Requirements for Block Schedules.

Uniform Complaint Procedures







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