Report 2021-101 Recommendation 7 Responses

Report 2021-101: K-12 Strong Workforce Program: State and Regional Administrative Shortcomings Limit the Program's Effectiveness in Supporting Grant Applicants (Release Date: February 2022)

Recommendation #7 To: Los Angeles Regional Consortium

To ensure that its selection committee follows safeguards designed to avoid unfair grant decisions, beginning with the fiscal year 2022-23 grant application period, the Los Angeles Regional Consortium should maintain internal documentation demonstrating its review for selection committee members' potential conflicts of interest. This documentation should include a comparison of the entities that applied and the conflicts reported by each selection committee member. The consortium should also keep records showing that selection committee members did not review applications for which they had conflicts of interest.

1-Year Agency Response

The LARC Chair and K14 Technical Assistance Provider (TAP) fully implemented a policy of keeping written records identifying the various entities that would benefit from each application if awarded. LARC will document the selection committee members who report having an interest in those entities and demonstrate that individuals with such an interest are not assigned to review those applications.

The policy was fully implemented for the 2022-23 K12 SWP selection process, LARC implemented the following policy with specific steps to guard against conflicts of interest.1. Before Calibration, each Selection Committee member completes the Selection Committee Agreement.2. K14 TAP pulls from Looker a report of the current round applications, along with the lead and partner LEAs on each application.3. K14 TAP cross checks the Looker report with Selection Committee employers and fills out the Potential Conflict of Interest Spreadsheet.4. K14 TAP sends the Potential Conflict of Interest Spreadsheet to the Selection Committee for them to add any other real or perceived conflicts of interest.5. When NOVA auto assigns Selection Committee reviews, the K14 TAP uses the completed Potential Conflict of Interest Spreadsheet to check for any real or perceived conflicts of interest. If any are present, the reviews are reassigned.6. K14 TAP maintains an Assignment Spreadsheet reflecting reassignments and final assignments.7. During Deliberation, Selection Committee members recuse themselves from any discussions or actions involving a real or perceived conflict of interest. Deliberation minutes reflect the recusals.

Documents/spreadsheets used to fully implement the policy were emailed to Bonnie Roy as attachments.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

Based on documentation of the consortium's efforts to guard against potential conflicts of interest for its selection committee, we assessed this recommendation fully implemented.

6-Month Agency Response

The LARC Chair and K14 Technical Assistance Provider (TAP) adopted a policy of keeping written records identifying the various entities that would benefit from each application if awarded. LARC will document the selection committee members who report having an interest in those entities and demonstrate that individuals with such an interest are not assigned to review those applications. Effective with the 2022-23 K12 SWP selection process, LARC adopted the following policy with specific steps to guard against conflicts of interest.1. Before Calibration, each Selection Committee member completes the Selection Committee Agreement.2. K14 TAP pulls from Looker a report of the current round applications, along with the lead and partner LEAs on each application.3. K14 TAP cross checks the Looker report with Selection Committee employers and fills out the Potential Conflict of Interest Spreadsheet.4. K14 TAP sends the Potential Conflict of Interest Spreadsheet to the Selection Committee for them to add any other real or perceived conflicts of interest.5. When NOVA auto assigns Selection Committee reviews, the K14 TAP uses the completed Potential Conflict of Interest Spreadsheet to check for any real or perceived conflicts of interest. If any are present, the reviews are reassigned.6. K14 TAP maintains an Assignment Spreadsheet reflecting reassignments and final assignments.7. During Deliberation, Selection Committee members recuse themselves from any discussions or actions involving a real or perceived conflict of interest. Deliberation minutes reflect the recusals. Documents/spreadsheets will be emailed to Bonnie Roy as attachments.

California State Auditor's Assessment of 6-Month Status: Pending

We appreciate the consortium's adoption of a policy and process to safeguard against potential conflicts of interest. Our assessment of whether it has fully implemented the recommendation is pending the consortium's submission of documentation demonstrating its review for potential conflicts of interest during the fiscal year 2022-23 application process.

60-Day Agency Response

The LARC Chair and K14 Technical Assistance Provider (TAP) adopted a policy of keeping written records identifying the various entities that would benefit from each application if awarded. LARC will document the selection committee members who report having an interest in those entities and demonstrate that individuals with such an interest are not assigned to review those applications. Effective with the 2022-23 K12 SWP selection process, LARC adopted the following policy with specific steps to guard against conflicts of interest.1. Before Calibration, each Selection Committee member completes the Selection Committee Agreement.2. K14 TAP pulls from Looker a report of the current round applications, along with the lead and partner LEAs on each application.3. K14 TAP cross checks the Looker report with Selection Committee employers and fills out the Potential Conflict of Interest Spreadsheet.4. K14 TAP sends the Potential Conflict of Interest Spreadsheet to the Selection Committee for them to add any other real or perceived conflicts of interest.5. When NOVA auto assigns Selection Committee reviews, the K14 TAP uses the completed Potential Conflict of Interest Spreadsheet to check for any real or perceived conflicts of interest. If any are present, the reviews are reassigned.6. K14 TAP maintains an Assignment Spreadsheet reflecting reassignments and final assignments.7. During Deliberation, Selection Committee members recuse themselves from any discussions or actions involving a real or perceived conflict of interest. Deliberation minutes reflect the recusals.

California State Auditor's Assessment of 60-Day Status: Pending

We look forward to reviewing documentation of the Consortium's use of its new process in its next response to this recommendation.

All Recommendations in 2021-101

Agency responses received are posted verbatim.