Use of Supplemental/Concentration Funds On a Schoolwide/LEA-wide Basis
1. Does the proposed use of funds increase or improve services for high need students (lowincome students, English learners, and foster youth) (i.e., does it “grow services in quality” or
“quantity”)?
a. Over the level of services provided to high need students last year (during the
transition to full LCFF implementation)?
b. Over the level of services provided to all pupils for the LCAP year?
2. Are the proposed use of funds “principally directed” toward meeting the goals that the LEA
has set in its LCAP for high need students? (In other words, are high need pupil goals the
principal purpose of the use?)
3. Can the proposed use of funds be demonstrated (by past experience, research, or theory) as an
“effective” use of funds for serving the LEA’s goals for high need students?
4. If the population of high need students in the LEA is below 55%, or in the school is below
40%, is the decision to provide the LEA-wide or schoolwide service the most effective use of
the funds, including compared to more targeted programs?
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(Does the LCAP provide the basis for the “most effective”

determination, including, alternatives considered and any supporting
research, experience, or educational theory?)
5. For annual updates and future LCAP adoptions, after a reasonable time for implementation:
(a) did the investment result in an increase or improvement in services in terms of program
quantity or quality as promised? (b) Was it effective (or, for low-concentration
schools/LEAs, the most effective use) in improving outcomes in the intended priority area?
If the answer to any of the foregoing questions is “no,” then the LEA should not propose to
spend (or continue to spend) supplemental and concentration funds on that service. Either, the
LEA should reject or discontinue the service or fund it with base funds.

 Prior Year Supplemental/Concentration Funding for High Need Students
The step in the 7-step proportionality calculation where LEAs have the most leeway to shape the
inputs into the calculation in ways that affect the LEA’s future obligation to increase or improve
services for high need students is at Step 2—i.e., in defining the prior year or baseline
expenditures on services provided for high need pupils. The more prior year services an LEA can
credit as having been provided for high need pupils (assuming those services will be continued),
the less the LEA needs to increase or improve services for high need pupils in new ways going
forward. As a consequence, LEAs and County offices should take particular care to ensure that
prior year expenditures in Step 2 are properly calculated. We recommend the following questions
regarding the LEA’s prior year expenditure calculation, both of which should be explored:
1. How did the LEA define the prior year (baseline) level of services for high need students in
2013-14?
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Did the LEA use only the prior (2012-13) level of Economic Impact Aid (EIA) or did the
LEA add additional services too?



If additional services beyond EIA were added, were those services targeted “for
unduplicated pupils” only like EIA or were they general across-the-board services
provided to both high need and non-high need pupils? (The latter should not be included
in 2013-14 prior year/baseline proportionality calculations under LCFF regulations.)

2. How did the LEA add to the prior year level of services for high need students each year after
2013-14 (i.e., for new high need student services added in 2014-15 and thereafter)?


Were the prior year services newly added in 2014-15 and beyond really “principally
directed” toward high need student goals or were they basic, across-the-board services
directed to the district’s goals for all pupils as with base spending?