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APRIL 2009
Public Advocates' SARC Audit Turns Up Evidence of Shortcomings
NUMBER 44 | APRIL 22, 2009
For the fifth consecutive year, the folks at Public Advocates have released the results of their SARC audit, conducted from Feb. 2 to Feb. 12.
Their findings are based on a narrow sample: 26 districts, covering 652 schools in just five counties. The scope of the audit was also narrow, limited to reviewing whether the following occurred:
Notable for its absence was any attempt by the audit team to determine the truthfulness or accuracy of the content of the accountability reports. This is surprising, given the attention to SARC accuracy in American Civil Liberties Union's annual review of Williams requirements. The first such report, written by ACLU's Brooks Allen in 2006, found that one-third of more than 450 SARCs sampled contained identifiable errors, inaccuracies, and omissions.
FINDINGS IN BRIEF
Public Advocates' findings are positive rather than critical. This is consistent with the tone of their release last year as well. They concluded that 87 percent of the districts surveyed had met the Feb. 1 deadline. In addition, they noted substantial gains in the rate at which districts met the translation requirement for SARCs - 81 percent this year, compared with 54 percent in the prior year.
The upbeat spin of the press release was small consolation for the ten districts singled out to get a letter demanding corrections. Yet the list of districts getting warning letters would have been much longer if Public Advocates had used all criteria that they reviewed. Instead, the attorneys' decision to issue demand letters to ten districts was based solely on whether those districts met the translation requirement for the SARC.
BACKGROUND
The annual audit reflects Public Advocates' interest in seeing the Williams legislation come to life. Together with the ACLU, Public Advocates led the Williams litigation that resulted in the five laws that settled the case. Interestingly, Public Advocates has been a key participant in the SARC reform task forces convened by the California Department of Education. In fact, their press release and report are a platform for their call for fundamental SARC reform.
Their reform agenda includes putting the responsibility for compliance monitoring squarely on the CDE's shoulders. It also includes a call for taking responsibility for SARCs away from districts and giving it to the CDE. This idea is not just a passing fancy. It's how accountability reporting works in almost every other state.
You can find their press release here, and the full audit report is available on their Web site.
RECOMMENDATIONS
Keep records of your SARCs' status as you publish them. The audit's findings are based on the condition of SARCs between Feb. 1 and Feb. 12. You may be posting documents in various states of completion prior to Feb. 1 and correcting errors you find later. Your ability to answer a legal challenge will rest on your records of the condition of your SARCs at any given time. Auditors make mistakes. You may defend yourself with greater success if your records are clear.
If you use other means to reach parents who read or speak languages other than English, document it. Districts have been coping with the escalating challenge of a multilingual California for several decades. Most districts have many ways to handle this, including using face-to-face translations on demand. Read the Ed Code section (EC 48985) that calls for strict translation of written documents and pass it to your district's counsel for review. Some districts choose not to translate their SARCs, but they manage the translation responsibility seriously at lower cost and to parents' satisfaction. Note that the CDE tightened their policy on translations a few years ago. They state on their Web site that only full-length versions of translated SARCs satisfy the Ed Code's requirements.
Take the accuracy of your SARCs seriously. Next year's audit from Public Advocates could be broader in scope. In an era marked by "truthiness" and too many people in government playing fast and loose with facts, it would serve districts well to be careful and thoughtful when entering their facts in the public record. There are others who read SARCs with a red pencil and a critical eye who care about this, such as advocacy organizations like ACORN, PICO, and Californians for Justice.
Take the accuracy of your financial facts extra seriously. In a moment like this, when most districts are in financial distress, any formal declaration about district or school expenditures, or teacher and administrator salaries, ought to be published with care. Your critics who may oppose parcel tax initiatives will fault your leadership for not knowing their own financial vital signs if your SARCs report financials sloppily. Be prepared.