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California State Auditor Logo COMMITMENT • INTEGRITY • LEADERSHIP

Youth Experiencing Homelessness
California’s Education System for K–12 Inadequately Identifies
and Supports These Youth

Report Number: 2019-104


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Birmingham Community Charter High School

October 23, 2019

RE: Audit Report 2019-104

Dear State Auditor:

The single school independent charter LEA of Birmingham Community Charter High School (BCCHS) is in receipt of your office’s report on its audit entitled “Youth Experiencing Homelessness” and identified as Report 2019-104.    We appreciate your careful and thorough review of our LEA’s Homeless Education Program including our identification of and services to youth who may be experiencing homelessness.  We have reviewed your report and we are responding to your recommendations as detailed further below.

Findings and Recommendations:

A. FINDINGS OF THE AUDIT:

  • The LEA (BCCHS) has under-identified youths experiencing homelessness.
  • B. LEA RESPONSE TO AUDIT RECOMMENDATIONS

  • The LEA is actively responding to the recommendations of the CA State Auditor regarding the housing questionnaire as detailed below:
  • The LEA is actively responding to the recommendations of the CA State Auditor  regarding the training of employees as detailed below:
  • The LEA is actively responding to the recommendations of the CA State Auditor by disseminating information explaining the educational rights of youth experiencing homelessness as detailed below:
  • Birmingham Community Charter High School is currently in the process of implementation of each of the above-referenced recommendations.  Under the advisement of your office, we hope to dramatically improve our homeless education program by increasing awareness of the issue, reforming the identification process and providing greater access to the services and supports afforded to youth experiencing homelessness.  We look forward to an ongoing partnership with your agency to ensure our continued growth in this important policy area.

    Please feel free to contact me if you have any questions or concerns. 

    Thank you,

    Ari Bennett, CEO/Principal
    a.bennett@birminghamcharter.com
    818.758.5202




    Comment

    CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM BIRMINGHAM

    To provide clarity and perspective, we are commenting on Birmingham’s response to our audit. The number below corresponds to the number we have placed in the margin of Birmingham’s response.

    1

    Throughout the audit process, we engaged in numerous conversations with Birmingham regarding our recommendations. However, until it submitted this response, Birmingham did not advise us of the actions that it now asserts to have taken to implement this recommendation. As a result, we were unable to review and analyze the changes it claims to have made to its website. However, we look forward to reviewing any documentation Birmingham provides as part of its 60‑day response to our recommendations to demonstrate the actions it has taken to implement this recommendation.





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    California Department of Education

    October 24, 2019

    Elaine M. Howle, State Auditor
    California State Auditor
    621 Capitol Mall, Suite 1200
    Sacramento, CA 95814

    Subject:  Youth Experiencing Homelessness - California’s Education System for K-12 Inadequately Identifies and Supports These Youth, Report Number 2019-104, November 7, 2019

    Dear Ms. Howle:

    The California Department of Education (Education) appreciates the opportunity to comment and provide proposed corrective actions for the recommendations outlined in the California State Auditor’s (CSA) Audit Report titled, Youth Experiencing Homelessness - California’s Education System for K-12 Inadequately Identifies and Supports These Youth.

    Perspective Comments

    2a
    1

    To provide additional perspective to the CSA’s audit report, Education has the following comments.

    Page 19:

    The source for the data displayed in the chart should also note that these data are publicly available on DataQuest, Education’s public data reporting website.

    3

    Education noted a few discrepancies with the data cited in the chart. The non-homeless dropout rate is 9.0%, not 6.0% as cited in the chart. Additionally, the percent of non-homeless students who “Did Not Graduate” is 16%, not 12% as cited in the chart. Education cannot confirm the corresponding LEA data citations provided in the report narrative because the LEA names have been redacted. As such, Education recommends that the CSA verify the corresponding LEA data citations provided elsewhere in the report narrative.

    4

    It is also important to note that some students who “Did Not Graduate” still completed high school through some other means than receiving a regular high school diploma or they returned as fifth year seniors to continue their high school education.
    Page 28:

    2b

    Both acronyms for the National Association for the Education of Homeless Children and Youth are incorrect. It should read NAEHCY, not NAECHY.

    5

    Also, in the first paragraph the last sentence states that the National Center for Homeless Education (NCHE) uses 5 percent of the economically disadvantaged student population as a reasonable benchmark for identifying students experiencing homelessness; however, Education informed the CSA that NCHE also uses 2.5 percent of the total student population as a reasonable benchmark for identifying students experiencing homelessness.

    6

    Education also informed the CSA that the most recent publicly available data (2013–14 and 2014–15) submitted by states to the National Center for Educational Statistics show that California ranks 2nd and 6th nationally using the first benchmark and 4th and 13th nationally using the second benchmark for the respective years. This information provides the necessary missing context to show how California performs in identifying homeless students relative to other states.

    Page 53:

    On the middle of the page it indicates that the state coordinator only reviewed between 12 and 21 LEAs for homeless education compliance. It is important to note that this is approximately 10 to 15 percent of the LEAs that are selected by Education for monitoring.

    Page 67:

    The second paragraph states that Education reserved less than 2 percent of its allocation for state level activities. It is important to note that Education does not determine funding for state level activities; this is done by the Department of Finance.

    Page 74:

    7

    In the middle of the page, the report states that “to gain reasonable assurance of the completeness of the data” the CSA compared the number of LEAs in the CALPADS point-in-time data with the number of LEAs in the cumulative end-of-year data. Because CSA found 18 more LEAs in the cumulative end-of-year data than in the point-in-time data, they concluded that the CALPADS data provided by Education was of undetermined reliability. In fact, the point-in-time and end-of-year are two separate data submissions in CALPADS with different business rules. Additionally, schools open and close throughout the year, which contributes to the observed differences in the data. It is not an indication that either CALPADS data source is of undetermined reliability.

    As previously mentioned, Education appreciates the CSA’s work on this topic and provides the following responses to the recommendations below.

    Recommendation 1

    To ensure that youth experiencing homelessness have access to the necessary services to help them succeed in school, by August 2020, Education should establish guidance for implementing data-sharing agreements between the LEAs and other organizations that provide services to these youth.

    Education’s Comments and Corrective Actions

    Concur. Education will strengthen existing website resources for youth experiencing homelessness by posting guidance regarding data sharing among LEAs and other agencies. Education is committed to ensuring that students have access to necessary services which will assist them in succeeding in school.

    Recommendation 2

    To ensure that it has the resources necessary to effectively meet its responsibilities under federal law, Education should complete a staffing analysis by May 2020 to determine the resources needed to meet its responsibilities for homeless education. This analysis should consider the resources needed to implement all of the recommendations in this report. If Education determines that it needs additional resources, it should take the necessary steps, including reallocating existing resources within the department, to secure the needed resources.

    Education’s Comments and Corrective Actions

    8

    Do not concur. As discussed with the CSA, Education already determined that additional resources were needed to meet its homelessness education responsibilities. The 2019 Budget Act authorized 1.5 FTE and an additional consultant was added to the Homeless Education program. At this time, Education does not anticipate needing additional resources for this program; however, if the homelessness education workload increases and more staff are needed, then Education will take the necessary steps to effectively meet our responsibilities.

    Recommendation 3

    To effectively monitor LEAs and help them identify additional youth experiencing homelessness, Education should do the following:

    To ensure that all LEAs receive necessary guidance and training, Education should perform the following:

    If you have any questions regarding the Education’s comments and/or corrective actions, please contact Kimberly Tarvin, Director, Audits and Investigations Division, by phone at 916-323-1547 or by email at ktarvin@cde.ca.gov.
    Sincerely,

    Lupita Cortez Alcalá
    Chief Deputy Superintendent of Public Instruction

    LCA:kl




    Comments

    CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM EDUCATION

    To provide clarity and perspective, we are commenting on Education’s response to our audit. The number below corresponds to the number we have placed in the margin of Education’s response.

    1

    We provided Education with a redacted draft report that contained only those portions relevant to it. Therefore, the page numbers that Education cites in its response do not correspond to the page numbers in our final report.

    2a
    2b

    As we do with all auditees, during Education’s draft review period we reached out to its staff and offered to work with them to discuss any factual or editorial changes to the draft report text, if warranted, to ensure that Education’s comments were constructive and focused on the recommendations. We are disappointed that Education chose to ignore our offer and instead chose to comment on areas that could have been handled through a simple telephone call.

    3

    We have revised Figure 2 and the surrounding text on page 14 regarding the rates at which youth experiencing homelessness dropped out or did not graduate. However, this revision did not change our conclusions. We have also revised the two instances on page 20 to correct the acronym for the National Association for the Education of Homeless Children and Youth.

    4

    Education’s comment seems to imply that the number of youth experiencing homelessness who did not graduate may be overstated, which would make the gap between graduation rates for these youth and their peers not experiencing homelessness less than the 31 percent and 16 percent rates shown in Figure 2 on page 14. Although we do not disagree with Education’s statement that some students who “Did Not Graduate” may complete high school through other means, this is true of all youth. As a result, we have no reason to believe that the disparity between the graduation rates among youth experiencing homelessness and their peers would be greatly affected.

    5

    We describe in detail on page 41 that the National Center for Homeless Education uses 5 percent of economically disadvantaged youth and 2.5 percent of total enrollment to determine whether an LEA is at high risk of underidentifying youth experiencing homelessness. In fact, as we state on that page, had Education used the National Center for Homeless Education’s method, it would have identified that two‑thirds of the State’s nearly 2,300 LEAs may be at high risk of underidentifying youth experiencing homelessness.

    6

    Education’s comment regarding its national ranking compared to other states obfuscates the fact that many California LEAs are failing to identify all youth experiencing homelessness. As we explain on page 20, our analysis of Education’s CALPADS data found that in academic year 2017–18 a majority of California LEAs—74 percent—identified less than 5 percent of their economically disadvantaged students as experiencing homeless. We considered this result to be indicative of Education failing to sufficiently oversee LEAs’ efforts to identify and provide services to youth experiencing homelessness. 

    7

    We stand by our conclusion about the reliability of Education’s CALPADS data. As we state on page 57, we follow the standards established by the U.S. Government Accountability Office, which require us to assess the sufficiency and appropriateness of computer‑processed information. We did not conduct a comprehensive data reliability analysis of CALPADS because the supporting documentation for its data is maintained among California’s approximately 2,300 LEAs, making such an analysis impractical. Further, on page 58 we describe that the limited data reliability analysis that we did perform—a comparison of the number of LEAs in Education’s point‑in‑time data to the number of LEAs within its cumulative end‑of‑year data—resulted in a discrepancy of 18 LEAs. Although Education claims in its response that the two data submissions have different business rules, it did not specify how these rules would affect this comparison. Regardless, because we could not determine the reliability of the data, we concluded that CALPADS data were of undetermined reliability, in accordance with the U.S. Government Accountability Office’s standards.

    8

    Although Education states in its response that at this time it does not anticipate needing additional resources for the program, the state coordinator told us during the audit, as we describe on page 50, that it still needs additional staff. We also conclude on that same page that Education has not clearly identified how many staff it needs to adequately meet its responsibilities under the homeless education program. Further, the governor vetoed Assembly Bill 16 in October 2019, which would have provided Education an additional 1.5 staff for its homeless education program. In his veto message, the governor noted that the need for additional staff was better considered during the annual budget process. Because Education would need to substantiate any request for additional staff when making a budget request, we believe that it is critical for Education to perform a staffing analysis to determine exactly how many staff it will need to meet all of its responsibilities for its homeless education program. Without such an analysis, Education lacks a basis to secure the necessary resources to administer the State’s homeless education program appropriately.

    9a
    9b

    Education’s assertion that it currently provides technical assistance to LEAs that report zero youth experiencing homelessness is grossly overstated. As we indicate on page 40, Education uses CALPADS data to identify those LEAs that report having zero youth experiencing homelessness enrolled in their schools. However, the “technical assistance” that Education provides to these LEAs is simply a letter that describes the federal reporting requirements for youth experiencing homelessness, defines homelessness under the McKinney‑Vento Act, and asks the LEA to ensure that future counts of youth experiencing homelessness are accurate. Besides this letter, the state coordinator does not provide any other technical assistance to support LEAs that report zero youth experiencing homelessness.

    10

    Education’s assertion that it currently reminds LEAs to disseminate information that describes the legal protections for youth experiencing homelessness is false.  As we state on page 44, neither the housing questionnaire nor the informational poster that Education developed for LEAs to use include information for parents and guardians about the legal protections afforded to youth experiencing homelessness.






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    Greenfield Union School District

    October 18, 2019

    Elaine Howle, CPA
    California State Auditor
    621 Capitol Mall, Suite 1200
    Sacramento, CA 95814

    Dear Ms. Howle,

    The Greenfield Union School District has reviewed the draft report, “Youth Experiencing Homelessness: California’s Education System for K-12 Inadequately Identifies and Supports These Youth”. The management team has provided a brief description of actions and practices that have or will be implemented as a result of the report recommendations.

    Our district will be working diligently to advance identification of students experiencing homelessness as well as adopt guidance and best practices provided by the National Center for Homeless Education (NCHE). 

    Greenfield is committed to provide needed resources and services to families experiencing homelessness and support all students to become successful and productive members of our community.

    Sincerely,
    Ramon Hendrix
    Superintendent

     

    Greenfield Union School District  Response to “Youth Experiencing Homelessness:”
    October 17, 2019

    Greenfield Union School District is dedicated to improving the McKinney-Vento (MV) program and practices. The LEA has implemented the following actions:

    Staff Training: MV & Signs of Homelessness Training will be provided to all staff and facilitated by the Director of Support Services (MV Liaison) and site Social Workers or counselors.

    1. Certificated: Includes administration, teachers, programs, and support staff
    2. Classified: Includes site clerical / program assistants, Nutrition Services, Family Resource Center, Maintenance Operations and Transportation
    1a

    Underidentified Youth Experiencing Homelessness: Greenfield Union School District has updated its procedures regarding dissemination of the Residency Questionnaire to all returning students. Questionnaires will be offered by school office staff any time a change of address is made by parent/guardian. Questionnaire forms were provided to all returning students as of August 2019.Based upon recommendations in the report, additional updates may be necessary.  

    1b

    Distribute Information about Educational Rights: Community Outreach within district boundaries was initiated. The MV Liaison initiated Community Outreach on June 24, 2019 and the District’s School Social Workers continued the distribution of information through September 11, 2019. Support Services maintains a list of contact names and locations where MV enrollment information and pamphlets were provided/posted.  District procedures will be developed to complete this process annually. 

    1. Medical Clinics, Library, Hotels/Motels, Local businesses (including laundromats, grocery and convenience stores, restaurants, gas stations)

    Shelters, food pantries, or soup kitchens are not located within district boundaries. However, Support Services has confirmed that MV posters were posted in public places by other LEAs.

    Website/Webpage: The LEA distributes the MV Enrollment poster available on the CDE website. The CDE website nor the Department of Education provide protection rights statements. The LEA will develop an updated MV poster to include Protection Rights.  LEA is currently working with the Information & Technology Department to update the website to include a webpage dedicated to MV that will include the name of the MV Liaison and resources for families experiencing homelessness.
    Separate page devoted to MV and educational rights
    Attach MV pamphlets and Residency Questionnaire
    Identified MV Liaison contact information
    Include protections set forth in federal / state laws

    Staffing: LEA will re-evaluate roles and responsibilities of the Director of Support Services / MV Liaison and support staff to determine any necessary adjustments needed to increase support, resources, and services to youth experiencing homelessness.




    Comment

    CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM GREENFIELD

    To provide clarity and perspective, we are commenting on Greenfield’s response to our audit. The number below corresponds to the number we have placed in the margin of Greenfield’s response.

    1a
    1b

    Throughout the audit process, we engaged in numerous conversations with Greenfield regarding our recommendations. However, until it submitted this response, Greenfield did not advise us of the actions that it now asserts to have taken to implement these recommendations. As a result, we were unable to review and analyze the changes it claims to have made. However, we look forward to reviewing any documentation Greenfield provides as part of its 60‑day response to our recommendations to demonstrate the actions it has already taken and any other actions it takes to implement these recommendations.






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    Gridley Unified School District

    October 22, 2019

    California State Auditor
    Elaine M. Howle, CPA
    621Capitol Mall Suite 1200  
    Sacramento, California 95914

    Re: Gridley Unified School District Response to State Auditor’s Report
    “Youth Experiencing Homelessness: California’s Education System for K-12 Inadequately Identifies and Supports These Youth”

    Dear California State Auditor:

    We appreciate the recommendations made by the state auditor’s office to help strengthen our systems and protocols for our students and families experiencing homelessness. We look forward to the continued implementation of these recommendations as we improve upon serving our homeless students and families.

    Sincerely,

     

    Jordan Reeves
    Superintendent
    Gridley Unified School District






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    Norwalk-La Mirada Unified School District

    October 24, 2019

     

    Elaine M. Howle, CPA
    California State Auditor
    621 Capitol Mall, Ste 1200,  
    Sacramento, CA 95814

     

    Re: McKinney Vento Audit

     

    Dear Ms. Howle,  

    The district is in receipt of your office’s report on its audit of the McKinney Vento program at Norwalk La Mirada Unified School District. The report notes some of our best practices; it also presents a few recommendations for our review.

    Enclosed you will find our responses to the recommendations identified from your report.

    If you have any questions, please contact me at (562) 210-2117.

    Sincerely,

    Patricio I. Vargas, Ph.D.
    Assistant Superintendent Educational Services
    Norwalk La Mirada Unified School District

    cc: Hasmik Danielian, Ed.D., Superintendent

     

    LEAs

    To comply with federal law and best practice, [Norwalk-La Mirada] should, before academic year 2020-21, do the following:

    Recommendation

    Response to the Recommendation
    The Norwalk-La Mirada Unified School District currently provides training to our principals, assistant principals, school counselors, psychologist, social workers, and enrolment staff on an ongoing basis. Training material includes the definition, signs, and impact of homelessness for families and youth. Additionally, we provide trainings to attendance clerks, counselors, and mental health providers. The Norwalk-La Mirada Unified School District will enhance its practices to ensure that teachers and other support staff will also receive training as federal law requires on an annual basis. This training will include, but not be limited to, the definition of homelessness, signs of homelessness, and the impact of homelessness on youth, as well as the steps staff should take to ensure we support youth experiencing homelessness.

     

    Recommendation

    Response to the Recommendation
    The Norwalk-La Mirada Unified School District currently disseminates our homeless education information via posters and flyers throughout the district in places frequented by students, parents and staff such as the front office, cafeterias and libraries.  The Norwalk-La Mirada Unified School District will expand its current practices regarding the distribution of information about the educational rights of youth experiencing homelessness in public places, including shelters and food pantries, frequented by families of such youth, as federal law requires. Additionally, the information will include the protections set forth in federal and state laws to mitigate families’ and youth’s hesitance to disclosing their living situation.

     

    Recommendation

    1

    Response to the Recommendation
    The information pertaining to the educational rights and protections of youth experiencing homelessness has been updated on the Norwalk-La Mirada Unified School District website as of October 24, 2019 under the Student & Family Services McKinney-Vento Program webpage.

    http://nlmusd.org/mckinney-vento/


    Comment

    CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM NORWALK-LA MIRADA

    To provide clarity and perspective, we are commenting on Norwalk‑La Mirada’s response to our audit. The number below corresponds to the number we have placed in the margin of Norwalk‑La Mirada’s response.

    1

    Because Norwalk‑La Mirada updated the information on its website at the time it provided its response, we were unable to review and analyze the changes it claims to have made to its website. However, we look forward to reviewing any documentation Norwalk‑La Mirada provides as part of its 60‑day response to our recommendations to demonstrate the actions it has taken to implement this recommendation.






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    San Bernardino City Unified School District

    October 24, 2019                                                                                Sent via Email and U.S. Mail:

     

    California State Auditor
    Attention: Elaine Howle, State Auditor
    621 Capitol Mall, Suite 1200
    Sacramento, California 95814

     

    Dear Ms. Howle:

    This letter serves as a written response to the California State Auditor’s draft report entitled “Youth Experiencing Homelessness: California’s Education System for K-12 Inadequately Identifies and Supports These Youth”, which details an audit conducted as the result of a Joint Legislative Audit Committee request.
    I would like to express my appreciation on behalf of the San Bernardino City Unified School District to you and your staff for the professional approach in conducting this audit and for the insight provided on opportunities for growth in how we serve one of our most vulnerable and deserving student populations.

    San Bernardino City Unified School District recognizes the areas of improvement needed in serving students in homeless situations as identified in the report and is committed to aligning district policies and best practices to all state and federal legislation pertaining to the rights and services for our students.

    In response to the recommendations in the report, SBCUSD will:

    I hope this response serves as evidence of our cooperation and commitment to serving all students experiencing homelessness in our schools.

    Respectfully,

     

    Angela Urquidies
    Director, Specialized Programs




    Comment

    CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM SAN BERNARDINO

    To provide clarity and perspective, we are commenting on San Bernardino’s response to our audit. The number below corresponds to the number we have placed in the margin of San Bernardino’s response.

    1

    Throughout the audit process, we engaged in numerous conversations with San Bernardino regarding our recommendations. However, until it submitted this response, San Bernardino did not advise us of the actions that it now asserts to have taken to implement this recommendation. As a result, we were unable to review and analyze the changes it claims to have made to its website. However, we look forward to reviewing any documentation San Bernardino provides as part of its 60‑day response to our recommendations to demonstrate the actions it has taken to implement this recommendation.






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    Vallejo City Unified School District

    October 23, 2019

    Elaine M. Howle, CPA
    California State Auditor
    621 Capitol Mall, Suite 1200
    Sacramento, CA 95814

    Dear Ms. Howle,
    Attached is my response to the audit report titled “Youth Experiencing Homelessness: California’s Education System for K-12 Inadequately Identifies and Supports These Youth.”

    Sincerely,

    Adam Clark, Ed.D,
    Superintendent


    October 23, 2019

    Dear Elaine Howle, California State Auditor:

    In response to the findings and recommendations within the "Youth Experiencing Homelessness: California's Education System for K-12 Inadequately Identifies and Supports These Youth," as related to the Vallejo City Unified School District, we agree with the findings and concur with implement the recommendations.

    Thank you,

    Adam Clark, Ed.D.
    Superintendent







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