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Explaining The LCAP, The Document At The Heart Of A $1 Billion LAUSD Fight

A student writes in his notebook in an L.A. Unified School District classroom in San Pedro on Aug. 21, 2017. (Photo by Kyle Stokes/KPCC)
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The Los Angeles Unified School District receives more than $1 billion each year in state funds meant to directly help three vulnerable groups: low-income kids, English learners and foster youth.

But for the second time in four years, LAUSD has been hit with a formal complaint accusing school district officials of doing a sloppy job explaining how they've spent this $1 billion.

And that's not all. The complaint -- filed in July by the law firm Public Advocates -- even raises the possibility that LAUSD misspent this money, potentially shortchanging programs meant to help those three vulnerable student groups in order to pay for across-the-board employee raises.

But this isn't just a fight over bureaucratic compliance. This is a fight over whether California's seven-year-old school funding system -- celebrated as a progressive achievement and a national model -- is working in the state's largest school district.

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It's also a fight that isn't going away.

In 2016, the California Department of Education sided with Public Advocates and others in a very similar complaint against LAUSD. (A year later, the district settled, sending $151 million in extra funding to 50 of its schools.)

At the heart of the fight is the document at the heart of the school funding formula: the Local Control Accountability Plan, or the "LCAP."

LAUSD has drafted amendments that address some of the concerns raised in the July complaint. The district board should vote on them soon.

LAUSD officials declined a request for an interview. In a written statement, district spokeswoman Shannon Haber said the amendments "are intended to provide more information to the public."

The amended version "actually reveals a lot of substantive problems we couldn't see before," said Public Advocates attorney Nicole Ochi. In an interview, Ochi said her organization may need to escalate its complaint.

But several academics who work with school districts statewide said LAUSD's difficulty addressing Public Advocates' persistent concerns also highlights weak points in California's LCAP process. LAUSD may need to adapt -- but they say the LCAP process may need to evolve, too.

In order to understand all of this -- both the complaints LAUSD has faced and the broader questions about the LCAP process -- let's take a step back:


The Local Control Accountability Plan is a document outlining how the school district intends to use its state funding to help those vulnerable groups of students mentioned earlier: English learners, foster youth and low-income kids.

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California funds schools on a per-student basis. Every student who fits into at least one of these "targeted" groups generates additional funding for their schools.

Districts have a lot of flexibility to use this extra money as they see fit, but with one major caveat: it must be spent on programs "principally directed" toward the English learners, foster youth and low-income kids who generated the money -- that is to say, on targeted services for targeted students.

So what counts as "principally directed?" The language is purposefully vague. If you hire a counselor to help low-income high schoolers get into college, but that counselor also sees other students who aren't in that targeted group, does that counselor's salary qualify as a worthy use of the state's extra funding?

This is where the LCAP comes in. Under state law, district officials use their LCAP to make the case that their spending plans actually serve the best interests of their most vulnerable students.

After the school board approves the LCAP, regulators in the County Office of Education then have to sign off; they're the ones who decide whether the school district has done an adequate job of justifying its spending plans.

FILE - California Governor Jerry Brown speaks during a press conference at the California State Capitol on March 7, 2018 in Sacramento, California. (Photo by Stephen Lam/Getty Images)


This is how it's been since 2013, when Gov. Jerry Brown and California lawmakers enacted the Local Control Funding Formula, or "LCFF" -- a top-to-bottom reimagining of how the state funds its public schools.

"The real philosophy," said Michelle Hall, a Chapman University researcher who did her doctoral dissertation on the origins of LCFF, "was that you give a block grant to the districts and they spend [the money] how they need to. If their student achievement goes up, they should be okay."

But "there was a lack of trust," Hall added, "that the districts would spend the money properly."

Hence the LCAP. If the new school funding system would be a wider road for districts to swerve across as they pleased, the LCAP would be the guardrails.

But academics, advocates and policymakers say that's just one of the purposes the LCAP was originally intended to serve:

  • The LCAP is supposed to force districts to justify their use of state funding.
  • The LCAP is supposed to compel districts to ask the community what it wants out of its schools.
  • The LCAP is supposed to help districts set goals for students' academic performance.
  • The LCAP is supposed to help districts outline its strategy to improve.

Some even argue the LCAP is supposed to be a means of decoding a district's budget. The LCAP shows how much targeted money a district is spending on a program -- for example, hiring those extra high school counselors. The LCAP can then show what measurable outcomes a district hopes to achieve with that spending -- such as "increased graduation rates" or "fewer dropouts."
Here's the issue, though, according to several academics studying the LCAP who spoke with KPCC/LAist:

"In trying to accomplish many of those things, the LCAP is not achieving any one of them well," said Joel Knudson of the American Institutes of Research (AIR), who runs a policy collaborative with California school districts.

That said, a recent survey showed that local school officials find the LCAP useful in certain ways; for example, four out of five California superintendents thought the LCAP was helping their district spend in line with its goals.

FILE - Los Angeles Unified School District superintendent Austin Beutner speaks with a student in the automotive program at Van Nuys High School on Tues., May 15, 2018. (Photo by Kyle Stokes/KPCC)

And in Los Angeles Unified specifically, assessing whether the LCAP is "working" is a question as complex as the district itself -- with little agreement among various stakeholders and academics about whether to pin shortcomings on the district, the LCAP itself, or both.

In her written statement, LAUSD spokeswoman Shannon Haber did not address this question directly, but did note the state has updated the template districts follow to write their LCAP plans. These changes were designed "to address concerns about compliance driven requirements and the need for greater transparency. These changes have made it difficult for districts to create continuity in the information shared."

"In an effort to do right by all kids, I think the LCAP has the unintended side effect of reinforcing a compliance mentality that can be restrictive of district progress," Knudson said.

Consider two of those original intentions the state's framers had for the LCAP -- and whether LAUSD's LCAP lives up to them.

PURPOSE #1: 'The LCAP is supposed to force districts to justify their use of state funding.'

This issue is core to Public Advocates' argument against LAUSD.

In their July complaint, the law firm -- which filed the complaint in the name of LAUSD parents Ana Carrion and Elvira Velasco -- argued that school district officials hadn't been specific enough about how they planned to spend $1 billion in extra state funding generated by English learners, low-income students and foster youth.

LAUSD is "failing to justify how the specific schoolwide actions are principally directed and effective for high-need pupils," Public Advocates' original complaint read, "and failing to assess the school-level actions for effectiveness after implementation."

Among the issues: Public Advocates identified $340 million in expenditures with dollars generated by high-need students that, the firm said, LAUSD has never justified as helping high-need students.

In response to the complaint, LAUSD has drafted a series of changes to its LCAP.

But Ochi, the Public Advocates attorney, said that these amendments have revealed a new problem: part of that $340 million, she said in an interview, appears to be underwriting broad salary increases for teachers and other district staff.

The California Department of Education has sent the (somewhat muddled) message that using targeted funds for across-the-board salary increases can be okay -- but the burden of proof is on the district to justify that the raises benefit high-need kids.

"I recognize the difficult position the district is in," said Ochi, who's an LAUSD parent herself. "But legally, [LAUSD officials] are also supposed to justify-- to say how this is helping high-needs kids, and they didn't do that. This expenditure is unlawful."

FILE - Students using devices at El Sereno Middle School in Los Angeles. (Photo by Chava Sanchez/LAist)

LAUSD officials declined an interview -- but the district does have its defenders, too, who have argued Public Advocates is essentially micromanaging LAUSD.

Public Advocates ultimately wants to ensure funds are allocated even more progressively to the highest-need schools. The district's defenders, who include many involved parents, say that push is impractical when even the most "affluent" schools -- by LAUSD standards -- serve sizable populations of needy students.

"It's kind of like the district can't win," said one such defender, Rachel Greene, in a 2017 interview with KPCC.

"I'm sympathetic to both sides," said UCLA education professor Pedro Noguera, because it's not always clear what types of approaches would work. For example, maybe English learners are best served by investing in salaries to pay for highly-skilled teachers to lead English learners' core classes. But that money could also arguably be spent well by paying for tutoring services for English learners.

Between options like these, Noguera said, "There's no clear agreement on what's the best way to address the need."

PURPOSE #2: 'The LCAP is supposed to compel districts to ask the community what it wants out of its schools.'

State law requires districts to consult with a Parent Advisory Committee and with a committee of English learner parents and advisors before passing the LCAP.

LCFF's framers hoped these consultations would lead to genuine back-and-forth, where parents, district officials and perhaps even students, teachers or community members could discuss their vision for the district.

To members of LAUSD's Parent Advisory Committee, their meetings could feel a little less high-minded.

"We were more of a compliance item," said Paul Robak, of Lomita, who has served three years on LAUSD's Parent Advisory Committee. "We perceived what some people call 'checkbox compliance.'"

One hurdle to getting parent engagement -- the document itself is dense. Have a look at the four-page summary beginning on page 2; the summary that's supposed to distill the full LCAP into a coherent "story."

Page 6 of LAUSD LCAP Amendments - Sept. 24, 2019

Contributed to DocumentCloud by KPCC Documents of Southern California Public RadioView document or read text

That's a lot of small font -- but consider yourself engaged, I guess?

Parents would submit feedback to the district's LCAP proposal.

"I want to be optimistic and say it was going to make a change," said fellow Parent Advisory Committee member Mayra Zamora. "But by the time [the parents' comments were] was submitted, the LCAP document has already been created."

Both Zamora and Robak said the district officials presenting and gathering parent feedback were helpful and would listen. But it also wasn't clear to Robak whether they were in a position to make change.

"The bureaucracy they're a part of," Robak said, "there's nobody who can look at the LCAP -- short of the superintendent -- and say 'this is ineffective.'"

In her statement, LAUSD's Haber said the district values the contributions of parents on the LCAP advisory committees, noting that the district recently relaxed its stringent volunteer requirements in response to their feedback.

"To the extent that PAC members feel constrained by committee procedures and rules," the statement said, "Los Angeles Unified will work with the committee to address those concerns."

Statewide, research suggests parent engagement efforts around the LCAP have been hit-or-miss. Julie Marsh, a professor at USC's Rossier School of Education, conducted a study of district efforts to reach out to parents during the first year of the LCFF's implementation.

Even today, Marsh said parent engagement around the LCAP "remains a struggle for a lot of districts, particularly districts that don't have a lot of experience doing [parent engagement] work."

But Ochi said there have been successes. After a lodging similar complaint against Long Beach Unified, she said that district has improved its LCAP process. Public Advocates also recently got involved in an activist push to stop the Pomona Unified School District from justifying expenditures on school police in its LCAP.

"The LCAP is working," said John Affeldt, a managing attorney at Public Advocates, contrasting these success stories from other districts with what he characterized as the dysfunction in the LCAP process in Los Angeles.

"LAUSD is fumbling," Affeldt added, "at how to keep itself solvent and follow the law at the same time."


District officials are "nearing completion of a 60-day investigation into Public Advocates' complaint and will issue a written investigative report shortly," according to their statement, released to KPCC/LAist Monday.

That response will likely determine whether Public Advocates escalates its complaint.

L.A. Unified School Board members had planned to vote Tuesday on amendments to the district's LCAP -- but the vote was postponed.

Ochi said the district had not posted its proposed amendments with the board's agenda and meeting materials, so board members might have run afoul of state public meetings laws had they approved them Tuesday.