Report 2021-101 Recommendation 8 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 #8 To: North/Far North 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 North/Far North 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

North Far North will maintain and further document the safeguards designed to avoid unfair grant decisions, internal documentation notes were improved starting 22-23. NFN safeguards were established during the most recent application process for individuals wishing to serve on the K12 selection committee, whereby applicants were required to disclose potential conflicts of interest. In reviewing and selecting new committee members, conflicts of interest were documented. These conflicts of interest are referred to in the assignment of applications for review by Selection Committee Chairs and K-14 TAP. In the 2022-23 grant review and award process, the K14 TAP and committee chairs checked for conflicts of interest before assigning grants to selection committee members for review, selection committee members will be required to confirm that no conflict of interest exists on any of the applications assigned, and committee members will recuse themselves from participating in any funding decisions where a conflict of interest exists. The NFN documented that these processes were followed in their audit files.

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

The consortium provided documentation of its process for identifying conflicts of interest and preventing participants from participating in decisions on applications from those entities the participants identified as presenting a conflict.

6-Month Agency Response

When applying for the Selection committee, the application has a conflict of interest declaration they must agree to.

Before reading applications, the SC members sign another conflict of interest form.

After random assignments from the State application system, "NOVA", the regional staff, along with the Selection Committee chairs, review assignments and adjust according to the member's geographical proximity to an applicant's. i.e. Far North region LEA's generally read North region's and vice versa.

Once reviewing applications has begun, a Selection Committee member can self declare a conflict and request to be reassigned. Generally this only happens if they realize their own LEA or a conflicting LEA was included on the application without their prior knowledge.

We have developed a conflict of interest matrix to document each conflict of interest, as that was the part missing from our process previously. We have always had a process and we implemented the documentation portion during the '21-'22 Selection Committee Review and Scoring period. In the past, we relied on NOVA for the documentation, as we track it there as well, but we have implemented a separate tracking sheet moving forward.

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

We recommended that the consortium document its comparison of entities that applied for grants and the conflicts of interest reported by each selection committee member. The consortium's response does not clearly indicate that it will do so. We encourage the consortium to ensure that the process it adopts fully addresses our recommendation, and we look forward to assessing the status of the recommendation when the consortium provides supporting documentation at the time of its one-year response.

60-Day Agency Response

North Far North will maintain and further document the safeguards designed to avoid unfair grant decisions, internal documentation notes will be improved starting 22-23. NFN safeguards were established during the most recent application process for individuals wishing to serve on the K12 selection committee, whereby applicants were required to disclose potential conflicts of interest. In reviewing and selecting new committee members, conflicts of interest were documented. These conflicts of interest are referred to in the assignment of applications for review by Selection Committee Chairs and K-14 TAP. In the 2022-23 grant review and award process, the K14 TAP and committee chairs will check for conflicts of interest before assigning grants to selection committee members for review, selection committee members will be required to confirm that no conflict of interest exists on any of the applications assigned, and committee members will recuse themselves from participating in any funding decisions where a conflict of interest exists. The NFN will document that these processes were followed in their audit files.

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

We appreciate the consortium's efforts to prevent unfair grant decisions. Per the timeline the consortium describes, it will implement conflict-of-interest safeguards starting in the fiscal year 2022-23 round of the grant competition. Accordingly, we look forward to the consortium's 6-month response and will assess the documentation it submits demonstrating its implementation of this new process at that time.

All Recommendations in 2021-101

Agency responses received are posted verbatim.