Audit Recommendations Disclosure

When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.

To ensure that charter schools appropriately address findings in extraordinary audits, the Legislature should consider requiring county offices of education to determine whether the findings are remedied within a reasonable amount of time. The Legislature should also require the county office of education to notify the chartering authority and CDE of each audit finding that it determines is unremedied in order to facilitate enforcement activities, such as the issuance of a notice of violation by the chartering authority or any necessary adjustments to apportionment by CDE.

Recommendation 8

To ensure chartering authorities are not placing themselves at financial risk, the Legislature should consider explicitly directing county offices of education, as part of their fiscal oversight responsibilities, to review how chartering authorities that authorize charter schools within their county fulfill their charter school oversight responsibilities.

Recommendation 9

To ensure that charter schools address misassignments and prevent uncredentialed teachers from negatively impacting students’ quality of education, the Legislature should consider requiring CDE, in collaboration with CTC, to assess fiscal penalties to chartering authorities when the charter schools they authorize repeatedly or consistently fail to address teacher misassignments.

Recommendation 10

To ensure that it is eligible to receive K-12 funding for its classroom-based instruction, Highlands should, by December 2025, implement a system that allows it to track how long its students are actually attending its classroom-based instruction.

Recommendation 11

To ensure that it is eligible to receive K-12 funding for its classroom-based instruction, Highlands should, by December 2025, establish a policy to structure its classroom-based courses in such a way that it provides classroom-based instruction for the duration of the class day as indicated in its bell schedules and requires its students to attend for the duration of the class day.

Recommendation 12

To avoid misreporting hours of attendance for those students who may rely on CalWORKs benefits, Highlands should, by September 2025, ensure that its policies and procedures for reporting student participation to county offices of human assistance for purposes of determining eligibility for assistance programs allow for and require accurate reporting.

Recommendation 13

To ensure that it reports accurate attendance information, Highlands should, by December 2025, create and implement written policies and procedures for how it reports ADA to CDE for funding, including details about which days should and should not be excluded.

Recommendation 14

To ensure that it reports accurate attendance information, Highlands should, by December 2025, create and implement written policies and procedures that require maintaining documentation such as sign-in sheets that support the attendance it records in its attendance reporting system for HCCS.

Recommendation 15

To ensure that it reports accurate attendance information, Highlands should, by December 2025, define what constitutes sufficient work products from CICA students and implement a policy ensuring that it only reports attendance for students who provide documentation for that work.

Recommendation 16

To ensure that Highlands spends K-12 funding appropriately, Highlands should, by December 2025, implement policies and procedures that outline the allowable uses of public funding, criteria for assessing and selecting vendors, and a purchasing process that includes separation of duties and requirements for multiple approvals.

Recommendation 17

To ensure that it does not execute inappropriate or wasteful contracts, Highlands should, by December 2025, implement comprehensive contracting policies and procedures that require multiple approvals, standardized contracting language, and proof of delivery of services.

Recommendation 18

To ensure that it does not violate state laws prohibiting conflicts of interest, Highlands should, by December 2025, implement a policy to provide annual conflict of interest training to all designated staff members and implement procedures to prevent employees from entering into contracts in which they have a financial interest, such as with a spouse.

Recommendation 19

To ensure transparency in its purchasing practices, Highlands should, by December 2025, revise its policies to require that all purchases and contracts over $115,000 be approved by the board. Highlands may adjust the amount annually in accordance with the state superintendent’s inflation-adjusted bid threshold amount.

Recommendation 20

To ensure that it hires employees with proper qualifications for their roles, Highlands should, by December 2025, implement policies and procedures that formalize its hiring process, including deciding on a position’s minimum qualifications before hiring begins, maintaining documentation of each step of the process for each candidate, standardizing the creation of job descriptions, implementing recruitment practices that include external and internal applicants, and standardizing the interview and job offer process

Recommendation 21

To ensure that no current employee at Highlands has the power to influence the hiring of their relative, Highlands should, by December 2025, require job applicants to assert whether they are related to a current employee at Highlands and require job interviewers to assert that they are not related to the individual they are interviewing. It should also develop or revise its policies to prohibit employees from being involved in the hiring and interview process for their relatives.

Recommendation 22

To ensure that pay is assigned equitably and based on merit and performance, Highlands should implement policies by December 2025 to create a merit-based structure for devising its salary schedules, evaluating staff, assigning salaries and salary increases, and deciding on annual bonus amounts.

Recommendation 23

To prevent favoritism and pay inequity, Highlands should, by December 2025, implement a policy to adhere to its salary schedules and not allow executive management to approve increases outside of salary schedule limits.

Recommendation 24

To ensure that students receive a quality education from credentialed teachers, Highlands should, by December 2025, document and implement a process to ensure that its teachers are properly credentialed and appropriately assigned to classes, including ensuring that paraeducators do not teach classes.

Recommendation 25

To ensure that Highlands’ instructors can provide students with a quality education through smaller class sizes, Highlands should, by December 2025, create a policy to establish an appropriate student-to-teacher ratio for its classroom-based instruction and calculate and monitor its ratios at both HCCS and CICA

Recommendation 26

To ensure transparency about its student outcomes and to avoid misleading its stakeholders, Highlands should implement a policy by December 2025 to comply with all School Accountability Report Card requirements, including the missing tables highlighted by CDE, and using the correct graduation rate methodology.

Recommendation 27

To comply with state law and provide transparency about the effectiveness of the education it provides, Highlands should, by December 2025, implement procedures to require participation in the California Science Test annually.

Recommendation 28

To ensure that Highlands’ students receive a quality education from appropriately credentialed teachers, Twin Rivers should, by December 2025, implement procedures to verify that its charter schools address and resolve identified misassignments within 30 calendar days, as state law requires.

Recommendation 29

To ensure that the charter schools it authorizes provide transparency about the quality of education they provide, Twin Rivers should, by December 2025, implement a mechanism in its annual oversight procedures to verify that schools meet the conditions of apportionment regarding participating in state testing requirements.

Recommendation 30

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that require staff to ensure that the charter schools it authorizes sufficiently address audit findings and recommendations, including reviewing documentation to verify that recommendations are implemented.

Recommendation 31

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that provide staff with expectations for reviewing and approving new and renewal charter petitions, including what constitutes a reasonably comprehensive description in the petition and what documentation staff must provide to the board to demonstrate the adequacy of their review.

Recommendation 32

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that require staff to conduct sufficient charter school oversight activities that align with state guidance and key best practices, and which, for key determinations, do not solely rely upon the annual audit or a charter school’s assertions. It should also require that the results of this information and a description of the methodology staff used for reviewing the items be summarized in the annual oversight reports.

Recommendation 33

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that require staff to ensure that charter schools obtain approval for material revisions of their charters when charter schools add new school site locations, grade levels, or other material changes described by state law.

Recommendation 34

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that outline the specific steps for investigating and resolving potential violations of state law or the charters, including that, upon the determination that a significant violation has occurred, Twin Rivers must provide the charter school with written notice of the violation that could lead to revocation of a school’s charter if not resolved.

Recommendation 35

To ensure that the schools it authorizes comply with state law and their charters, and that staff and officials are aware of Twin Rivers’ expectations in conducting such oversight, by December 2025, Twin Rivers’ board and management should create and implement comprehensive policies and procedures that require staff to establish a method for tracking Twin Rivers’ actual costs for charter oversight and collect only the oversight and facilities fees allowed in state law.

Recommendation 36

To ensure that schools participate in their required testing and to ensure transparency about student assessment outcomes, by December 2025, CDE should propose including a procedure in the K-12 audit guide to verify that schools meet the condition of apportionment regarding participating in state testing requirements.

Recommendation 37

To ensure that it takes appropriate action related to Highlands, the state superintendent should direct CDE to immediately investigate whether Highlands has sufficiently complied with state law, met the conditions of K-12 funding, and appropriately claimed K-12 funding. To the extent that CDE determines that Highlands has failed to significantly address the audit findings in this report and others, or that Highlands has committed any violations of state law, has not met the conditions to receive K-12 funding, has not demonstrated improved pupil achievement, or inappropriately claimed K-12 funding, the state superintendent should take appropriate action, including pursuing adjustments to Highlands’ apportionments and making a recommendation to the State Board of Education to take appropriate action, up to and including revoking Highlands’ charters.

Recommendation 38

To ensure that LEAs, including charter schools, resolve teacher misassignments as state law requires, by December 2025, CTC should initiate promulgation of regulations defining the standards for LEAs that consistently misassign educators and what sanctions CTC may impose on those agencies.

Recommendation 39

To ensure that the audits it requests lead to meaningful reductions in identified deficiencies, the Sacramento COE should, by December 2025, implement procedures to verify that all LEAs within the county’s jurisdiction sufficiently address audit findings and recommendations from those audits, such as by reviewing documentation or following up to verify that the agency addressed the findings and recommendations.

Recommendation 40

To ensure that chartering authorities within its county are not placing their financial stability at risk through insufficient oversight of the charter schools they authorize, the Sacramento COE should, by December 2025, implement procedures for reviewing how chartering authorities fulfill their charter school oversight responsibilities.