October 23, 2019
Ms. Jo Ann Isken, Chair
Dr. Ilene Straus, Liaison to the State Board of Education
California Practitioners Advisory Group
California State Board of Education
1430 N Street, Suite 5111
Sacramento, CA 95814
Via email only (sbe@cde.ca.gov and cpag@cde.ca.gov)
Re: Revisions to the Local Control and Accountability Plan Template and Instructions
Dear Ms. Isken and Dr. Straus:
We thank the Board and CDE staff for sharing interim drafts of the Local Control and Accountability Plan
(LCAP) Template Revision Prototype and instructions to get feedback from interested stakeholders.
Additionally, we appreciate that the LCAP Template and instructions adoption will be delayed until
January 2020. At this point we believe providing the extra time for input from stakeholders will result in
an improved template. We continue to have the same concerns which we raised with the Board at its
September 2019 meeting, as well as additional comments focused mainly on the initial draft of the
template instructions that were not available prior to the September Board meeting.
Below we highlight in detail three key pieces of feedback on the template and instructions, that reflect
our strongest concerns. This letter will then identify numerous additional areas where specific
improvements could be made to the template.
THREE CRITICAL DEFICIENCIES
Major Progress on “Increased and Improved: Services Requirements” (and related instructions)
The improvements to this section are significant. The change in the prompt makes it clear that the use of
local educational agency (LEA)-wide or school-wide flexibility must ensure that the justification of the
use of this flexibility, and the related actions, will ultimately be principally directed to meeting the needs
of Low-income students, Foster Youth and English Learners (ELs). We encourage the Board to maintain
these changes and suggest the following additional edits which would ensure that not only were the
needs of these populations considered, but they were prioritized, and the actions were directed to
support these groups.
“For each action being provided to an entire school, or across the entire school district or
county office of education, provide an explanation of how the needs of English learners, foster
youth, and low-income students were prioritized considered first before selecting each action
being provided to an entire school, or across the entire school district or county office of
education, and how these actions will be effective in meeting the goals for these students.”
While the instructions for this prompt are very clear that this justification must be provided “for each
action,” the template prompt could help districts make sure they meet this requirement for each action
by creating additional cells in the prompt.
Action #. [Provide Description here]
Action #. [Provide Description here]
Action #. [Provide Description here]

 Ms. Jo Ann Isken
Dr. Ilene Straus
October 22, 2019
Page 2
To date, districts have done a poor job of providing this justification for each action in their LCAPs, which
has been a sticking point for the equity community. The proposed delineation also would help to focus
the attention of the county offices of education (COEs) as they review their district’s LCAPs.

“Goals: Measuring and Reporting Results”
We encourage the CPAG members to consider the timing of the LCAP adoption (May/June annually),
and the timing of the release of data for the state indicators (Fall to December annually). These
recommendations apply to both Option A and Option B.
• Clarify Baseline. The “Baseline” instructions should clarify that the most recently available data
should be reported (in most cases for the June 2020 LCAP, this will be 2018-19 data and not
2019-20 data – as currently appears in the instructions).
• Add Column “Actual Outcome for 2019-20.” We recommend including an additional column
that would be reported as part of the annual update for the June 2021 LCAP update and reflect
actual outcomes. In June 2021 (the first LCAP update), districts won’t yet of have any data for
the “Actual Outcome for 2020-21”, so there will be no data reported in the update as it
currently stands. The 2020-21 actuals will be available for the second LCAP update in June 2022.
Thus, for the first LCAP update, we recommend adding a data reporting column “Actual
Outcome for 2019-20” that can be used to inform any adjustments that a district would make to
its action or implementation plan.
“Goals: Actions” – Add Separate English Learner Prompt
Consistent with the 2018 Budget Trailer Bill requirements, the proposed instructions state that all LCAPs
with a numerically significant EL subgroup must include specific actions in the LCAP. The instructions are
unclear in the guidance for how a district would let stakeholders know which specific actions are
meeting this requirement. We believe it would be cleaner to create a separate prompt in the LCAP
template to address this requirement instead of having it separated in the “Goals: Actions” instructions.
Under the current approach, a parent or stakeholder interested in actions targeted for ELs would have
to review the details of every action to try to figure out whether the requirement for ELs had been met
and how it was met. If a separate prompt were created, a concerned parent could determine this much
quicker and have a more holistic perspective on the proposed actions.
Two approaches could be used to effectively meet this statutory requirement:
•

•

Approach 1. In the “Focus Goal(s)” section, add an additional subsection:
“Actions Supporting Language Acquisition Programs and English Learner Related
Professional Development” - Include Action “#, Title, Description, Total funds,
Contributing” prompt boxes for this subsection
Approach 2. In the “Actions” subsection add an additional prompt similar to the “Contributing
(Y/N)” prompt “Language Acquisition Programs and English Learner Related Professional
Development (Y/N)”

Additionally, we recommend that the SBE add prompts that can be framed as “LEAs are encouraged to”
around specific actions and services that are being providing to Foster Youth and similarly for Low
Income Students. We believe this is warranted given the requirement to “Increase and/or Improve
Services” for these unduplicated student groups and that it will allow LEAs to receive credit for work
they are doing to support these students.

 Ms. Jo Ann Isken
Dr. Ilene Straus
October 22, 2019
Page 3

SECONDARY CONCERNS WITH THE DRAFT TEMPLATE & INSTRUCTIONS
Below we offer additional comments, which follow the order in which they appear in the template and
accompanying instructions.

“Plan Summary” Section
“Reflection: Identified Need”
For this section, we encourage edits to the instructions to do two things:
• The current instructions focus only on areas with red/orange performance or achievement gaps
as defined. We hope that over time, fewer districts will have very low performance or
achievement gaps. At the same time, every district should be able to identify some area that it
has identified as an area of need that will then be reflected later in the LCAP document as the
focus of its goal setting and actions. For those districts that don’t have very low performance or
achievement gaps, we recommend adding an instruction such as “If your LEA doesn’t meet any
of the criteria above, please describe the areas that your LEA has identified as its area of need
and the steps the LEA is planning to take to address those needs.”
• The section should link to the district support and assistance process. It should let the plan
reader know if a district is receiving support and assistance from its county office of education,
for how many years it has been receiving assistance, and for which subgroups and what
indicators. We recommend adding the following instructions to prompt: “If your LEA has been
identified for district differentiated support, indicate the number of years the district has been
receiving support, and identify the subgroups and indicators that have led to this
identification.”
“Comprehensive Support and Improvement (CSI)”
• “Schools Identified”: The instructions should require that along with identifying which schools
qualify for CSI, the LEA should additionally report the indicators that led to its identification
(red/orange designations for which indicators). We recommend amending the instructions as
follows: “Schools Identified: Identify the schools within the LEA that have been identified for CSI,
and the indicators and Dashboard color ratings that resulted in the schools being identified.
• “Support for Identified Schools”: The instructions provide an opportunity to integrate the CSI
planning process and the LCAP planning process. Ideally, actions delineated in the LCAP should
support these CSI schools. We recommend adding the following to the instructions. “What
actions in the LCAP support the CSI plans?”

“Increased or Improved Services” Section
“Increased Apportionment”
The revised template states “Increased Apportionment based on the enrollment of Foster Youth, English
Learners and Low-income students”. It is unclear what this is in reference to: does this “Increased
Apportionment” refer to the increase in Supplemental and Concentration grant funding from the prior
year, or does it reflect the total Supplemental and Concentration grant amounts? This section could be
rephrased to clarify the meaning. A suggested rephrasing would be to simply state “Total Supplemental
Grant and Concentration Grant Apportionment based on ….” or “Total Apportionment based on the
enrollment of…”

 Ms. Jo Ann Isken
Dr. Ilene Straus
October 22, 2019
Page 4

Additional LCAP Requirement
Require LCAP to Be Machine Readable PDF
In past LCAPs, some districts have converted their LCAP plans into a non-readable format, which means
that parents who were interested in a specific issue were not able to perform a key-word search, but
instead needed to read the entire document to find what they were looking for. If the document were
required to be machine readable, then a stakeholder could easily search the document for specific areas
of interest, for example, searching for English learners or restorative justice.
In closing, we note that the LCAP is seen one of the central communication tools between a district and
its stakeholders; as such, the work of drafting the template appropriately is of great importance. Thank
you for undertaking this work and considering the input of interested stakeholders in the revision
process.
Sincerely,

Robert Manwaring
Senior Policy and Fiscal Advisor
cc:

Members, California Practitioners Advisory Group
Members, State Board of Education
Karen Stapf Walters, Executive Director, SBE
Judy Cias, Chief Counsel, SBE
Dave Sapp, Deputy Policy Director and Assistant Legal Counsel, SBE
Sara Pietrowski, Policy Consultant, SBE
Lupita Alcala, Chief Deputy Superintendent, CDE
Stephanie Gregson, Deputy Superintendent, CDE
Jeff Breshears, Education Administrator Local Agency Systems Support Office, CDE

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