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research spotlight

By Mary Gardner Briggs

Drowning in Documentation
For years, school district leaders sounded the alarm: Student needs have multiplied in the wake of the pandemic; hours in the day remain finite; and yet, local educational agencies are expected to complete an ever-growing number of plans, reports and data submissions.

And while you may have heard grumblings about “the plandemic,” the story of the cumulative impacts of these requirements remains largely untold.

The logic underlying the system is reasonable: Ensure LEAs use public funding responsibly, monitor outcomes for continuous improvement and plan local initiatives that are consistent with the most pressing state priorities. Unfortunately, implementing it piecemeal over time, while rarely removing or simplifying existing requirements, has snowballed into an unsustainable workload that undermines LEAs’ ability to focus on their core responsibilities. As one small school district board member told CSBA’s Research and Education Policy Development (REPD) team:

Planning and accountability are essential. This isn’t a screed against that. It’s shining a spotlight on the fact that the balance between doing education and doing accountability is way out of whack and is having a seriously detrimental impact, not just directly by taking administrators away from the real work, but in employee morale all the way through districts’ ranks when teachers, staff and site administrators aren’t getting the support they need. Doing reports is not doing leadership. And leadership is the answer to raising LEA performance and achievement. Full stop.
To help policymakers visualize the full picture, CSBA released a fact sheet in May. “Drowning in Documentation: Reporting Requirements for California LEAs” highlighted the scope of the requirements, both in number and frequency, by compiling a comprehensive list of key federal and state reporting requirements. This report has been used by governance teams and administrators across the state to advocate for a more effective and practical system.

CSBA’s Governmental Relations Department also used it in their advocacy for Senate Bill 1315 (Archuleta, D-Pico Rivera). Co-sponsored by CSBA and the California Association of School Business Officials, the bill requires the California Department of Education (CDE) to document and report to the Legislature the number of state and federally mandated reports that LEAs must submit. The CDE must also include the purpose of each required report, along with recommendations for consolidating, abbreviating or eliminating reports. The bill was signed by Gov. Gavin Newsom on Sept. 22.

Despite the fact sheet’s reach, a list alone can’t offer guidance for improving the system. Thus, the REPD department worked with local and state leaders to gather data about how these requirements impact LEAs at the local level. A new report, Drowning in Documentation: Toward More Effective and Manageable Reporting for California LEAs, is the result of that research.

Researchers spoke with administrators from a range of school districts and county offices of education. The smallest participating district serves fewer than 100 students, while the largest serves more than 60,000. County office participants added to district perspectives, since they are responsible for their own reporting, as well as working with their local districts. State agency and legislative staff shared insights about challenges and recommendations from the state perspective.

Among key findings, the report details the cumbersome nature of existing requirements, including issues with volume, timing, redundancy and frequency, along with issues moving between outdated data systems and the time spent adapting to changing requirements. No one report presents an undue burden; taken together, however, the workload draws administrators away from other core responsibilities. Small school districts, in particular, noted the disproportionate impact on their limited number of staff.

Participants also spoke to the time required to develop narratives and plans from scratch, especially when incorporating opportunities for authentic stakeholder engagement. Acknowledging the worthy goals of planning and engagement, respondents described a desire for streamlining document elements, particularly the Local Control and Accountability Plan (LCAP) and Comprehensive School Safety Plan, both of which have required components added frequently.

Additionally, those interviewed spoke about the shift away from the logic and intent behind the Local Control Funding Formula (LCFF), particularly by a return to a reliance on new categorical or one-time funds, each associated with their own reporting requirements (and in many cases, additional plans). With the LCAP, the continued addition of components resulted in documents so cumbersome that they fail to be meaningful tools for guiding or communicating local improvement efforts. Driven by deadlines, administrators reported many elements have become an exercise in compliance, rather than authentic strategic planning.

Those interviewed also spoke about systemic issues with one-size-fits-all requirements, limited feedback loops between different levels of the system, and a lack of individuals responsible for a holistic evaluation of requirements and ensuring the data is used effectively, if at all.

The people responsible for creating and submitting these reports also offered suggestions that informed CSBA’s recommendations. Among them:

  • Recommit to the logic of LCFF by:

    • Reconsidering the use of categoricals outside of LCFF; and
    • Committing to a three-year goal of significantly reducing the number of data elements in the LCAP.
  • Reduce the reporting load by:

    • Conducting a comprehensive review of current requirements, aiming to reduce time spent on reporting by at least 25 percent;
    • Prioritizing the removal of redundancies and data elements that are not actively used for decision-making;
    • Considering district size when determining reporting obligations, including waiving some reports for districts with an enrollment of fewer than 1,000 students; and
    • Better distinguishing and defining the purpose of the audit system versus tracking expenditures.
  • Increase support for LEAs by:

    • Shifting some data compilation responsibilities to higher levels (county or state) and making greater investments in technology, particularly data systems;
    • Developing sample content for required plans that LEAs can adopt or adapt;
    • Enabling very small districts to choose an intermediary to complete plans or reports on their behalf; and
    • Normalizing and providing guidance for using artificial intelligence to generate content at the district level and harvest insights from data at the state level.
  • Develop better feedback loops between the state and LEAs by:

    • Establishing standing advisory groups that provide opportunities to weigh in on existing requirements and future changes;
    • Encouraging statewide associations to compile annual lists of minor issues that could reduce administrative burden through statutory changes; and
    • Regularly analyzing State Board of Education waiver requests to identify common challenges and potential statutory fixes.

Ultimately, CSBA is committed to developing research that has a positive impact. This research provides in-depth insights and recommendations for policymakers. The new report was included in a legislative briefing in October and is being used in an ongoing education campaign to encourage the Legislature, Governor, State Superintendent of Public Instruction and other state policymakers to make substantive reforms for a more coherent and thoughtful approach to holding LEAs accountable for planning and implementing educational improvement efforts.

Mary Gardner Briggs is Senior Director of the CSBA Research and Education Policy Development Department. Questions? Contact research@csba.org.
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