Report 2021-101 Recommendation 9 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 #9 To: South Central Coast 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 South Central Coast 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

In particular response to #9 COI documentation, the SCCRC will maintain the following internal COI documentation—1) signed COI forms completed by Review Team and Selection Committee members, 2) comparison of entities that applied to be on the Selection Committee by sub-region and by college service area. A color-coded spreadsheet has been created that shows applicants by geographic sub-region and by college service area. This spreadsheet will be used by the Review Team when selecting the Selection Committee members for the 2022-23 Round 5 K12 SWP, and 3) spreadsheet showing conflicts identified for each member and documentation that members will not score applications where conflicts are noted. Regional Chair and K14 TAP are responsible.

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 South Central Coast Regional Consortium agrees has updated its processes regarding documentation and reporting of conflicts of interest for the K12 SWP review team and selection committee members. This documentation now includes comparison information of the entities that have applied and documents any conflicts as reported by members. Records will be kept documenting any conflicts selection committee members may have including a statement of ascertaining no conflicts.

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

We appreciate the consortium's update to its 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 South Central Coast Regional Consortium (SCCRC) convened the Regional Review Team of high-level K12 and community college administrators and the Regional Selection Committee on March 16th to present audit findings and discuss next steps for response and compliance with the response timeline (see supporting documentation titled: K12 SWP Audit PPT). The next Review Team meeting will be held on April 19 and the agenda for that meeting includes: 1) review and approval of the revised Conflict of Interest (COI) form (see supporting documentation), 2) review of the COI spreadsheet for assigning grant application readers showing comparison of entities that applied and conflicts identified for each member (see supporting documentation spreadsheet). The April 19th meeting will also include the finalization of Review Team members' votes selecting the Round 5 Selection Committee.

In particular response to #9 COI documentation, the SCCRC will maintain the following internal COI documentation—1) signed COI forms completed by Review Team and Selection Committee members, 2) comparison of entities that applied to be on the Selection Committee by sub-region and by college service area. A color-coded spreadsheet has been created that shows applicants by geographic sub-region and by college service area. This spreadsheet will be used by the Review Team when selecting the Selection Committee members for the 2022-23 Round 5 K12 SWP, and 3) spreadsheet showing conflicts identified for each member and documentation that members will not score applications where conflicts are noted. Regional Chair and K14 TAP are responsible.

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

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

All Recommendations in 2021-101

Agency responses received are posted verbatim.