The research resulted in a report, Drowning in Documentation: Toward more effective reporting for California districts, which produced a non-exhaustive list of required reports and plans on a range of topics, including myriad additional plans and reports for any discretionary grants and programs. Examples of regular reports include the Local Control and Accountability Plan (LCAP), School Plan for Student Achievement, School Accountability Report Card (SARC), California School Dashboard and local indicators, Home to School Transportation Plan and the Comprehensive School Safety Plan, on top of a plethora of requirements around special education. Additionally, state block grants and special funds — like the Expanded Learning Opportunities Program and Proposition 28: Arts and Music in Schools — require report submissions. Also included are required data submission and compliance activities that staff must submit on an ongoing basis throughout the year. And layered on top of all these requirements are California Public Record Act requests that LEAs receive regularly.

“Increasingly, CSBA members have expressed that California’s Byzantine reporting system is interfering with their capacity to focus on their core responsibilities, and often with little benefit in terms of accountability,” CSBA CEO & Executive Director Vernon M. Billy said. “While accountability and transparency are vital to our public education system, Drowning in Documentation demonstrated that the sheer volume and ever-growing list of required reports is overwhelming school districts and county offices of education. Feedback from the field confirms that educators and administrators are increasingly torn between managing this paperwork and focusing on their primary obligations to students, staff and communities. For smaller districts, this issue is especially acute, pulling their limited number of staff away from serving students.”

Ultimately, the goal of the report and accompanying CSBA-sponsored legislation is to identify strategies for streamlining reporting processes, reducing duplicative reporting and allowing educators to focus on what matters most: improving student outcomes.

The logic underlying reporting requirements is sound: to ensure LEAs use public funding responsibly, outcomes for continuous improvement and local plan implementation in line with state priorities must be monitored. The reporting systems in place prior to the groundbreaking Local Control Funding Formula (LCFF) existed to ensure that categorical program funding was being spent in the way it was intended. LCFF was implemented to grant more flexibility to local decision-makers to spend their funding in a way that best supports their local needs.

“LCFF’s original intent was to give people more flexibility in how local districts spend their dollars, and one bonus of that was instead of having 40 to 60 different things that you’re reporting expenditures on and having to make sure that they’re in the right category, reporting was streamlined,” said CSBA REPD Senior Director Mary Gardner Briggs. “And there was some initial success with LCFF, but we have seen categoricals creep up over the years.”

Briggs cited two main reasons for this categorical creep: legislative incentive and one-time funds. She and CSBA Legislative Advocate Dan Merwin cited the trend of newly elected lawmakers wanting to “leave their mark” on an issue with related legislation, and that tends to be a categorical program with its own planning and reporting requirements.

“When you look at a new initiative in a vacuum, the associated compliance burden may seem reasonable,” Merwin said. “But they’re not seeing the whole picture. I think the challenge is that as the legislative changes and their priorities shift, there isn’t a deeper reflection on how a new priority does or does not fit within the existing system — it just gets layered on top of everything else and continues to grow. One example is the LCAP, which began around 12 pages and now is well over a hundred pages.”

WestEd researcher and University of the Pacific Professor Jason Willis examined just how much time reporting and compliance activities require of LEA staff. Using survey data from over 900 LEA administrators for the Stanford SCALE initiative Getting Down to Facts III, he estimates that central office administrators spend approximately 20 hours per week on compliance activities — about 39 percent of their typical workweek — amounting to roughly 151,000 hours statewide per week. He estimates this represents an annual statewide opportunity cost of between $2.73 billion to $3.56 billion in personnel time.

He found that this work is concentrated in a small number of activities, with special education, financial reporting, LCAP, student support programs and human resources activities accounting for 42 percent of total compliance hours.

In the two LEAs CSBA spoke to for this story, that amount of time varied by their size and by the time of year.

The Fresno County Superintendent of Schools (FCSS) office is a leader in the field, providing dedicated service and guidance to its districts in support of fulfilling reporting and compliance requirements. It surveyed each of its districts and found that the larger ones like the Clovis and Fresno unified school districts had a single point of contact for state and federal accountability work. For its small and rural districts, the county office found they spend about 30 percent of their time on compliance work.

“We asked, ‘How many hours per week would you estimate that you spend on state and federal compliance tasks, reports, plan writing, collecting data and expenditures to use for plans and reports, et cetera?’” said FCSS Associate Director of Educational Innovation and Support Dana Budd. “And many have said closer to 20 hours around the big reporting time. For example, once December hits and we’re looking at the SARC, the safety plan, the mid-year report, it’s sometimes LCAP season — it can be sometimes upward to 30 to 40 hours a week.”

FCSS is able to dedicate staff specifically to helping its districts fulfill requirements, allowing them to focus on the instructional program. “What’s happening in classrooms with the teachers and students is the most important thing that happens,” said FCSS Assistant Superintendent of Educational Innovation and Support Corey Greenlaw. “And we work very hard at Fresno County Superintendent of Schools to remove burdens and remove barriers to allow an administrator to get into that classroom. The reason we can do that is because of the vision of our past superintendents who’ve set up these systems.”

Greenlaw said one of the funding sources for these specialized positions is through differentiated assistance funding granted to the county office to provide services to its districts that may be struggling in these areas. “If you go up north into some of my really small county offices, they just don’t have the resources or the funding to be able to provide some of these services,” Greenlaw continued. “Size and context really do matter in those situations.”

That sounds about right to Bryan Easter, who offers a unique perspective as the superintendent of Maple Elementary School District and a board member in the Panama-Buena City Union SD, both located in Kern County. Maple ESD, a one-school district, serves 283 students, while the 19-school Panama-Buena City serves 19,351 students.

“Timing is a huge thing,” Easter said, naming the cluster of requirements when the mid-year LCAP report is due, along with the second interim budget, Dashboard components and other ongoing compliance activities. “A huge difference that I see between the two districts is when you’re by yourself as a superintendent or superintendent-principal, it all falls on you at once. And then in your bigger districts, even though it falls on the district at once, people are operationally designated to take care of it.”

WestEd researcher Willis found another consequential difference between how administrators handle the compliance workload in small versus larger districts. “What we were also finding is that it wasn’t just the actual time that was creating strain on administrators, but it also was this notion of attention loss and psychological strain,” Willis explained. “This ‘code switching’ that people have to do across activities, there’s a cognitive load that accumulates for people. And if they’re feeling pressure to have to also do all kinds of things that are happening outside of the compliance time — they’re having to plan, they’re having to do more student-facing work — that time is getting squeezed, and it’s basically pushing their psychological stress even higher.”

That experience is true to life for Easter. “When you’re in a larger district and you’re at the district office, your door is closed and you get your report done. When you’re a small district, you’re handling student discipline, you’re helping serve lunch — you’re constantly being pulled away from that report,” Easter said. “And when you’re doing reporting, that last thought leaves your mind because you’re having to go deal with a kid on the playground, so it takes more time. That is one of the biggest differences, when you’re in a small district, you’re at the school and you have day-to-day business you have to take care of. In a larger district, your worries are really surrounding that reporting and the district office business.”

In September 2024, Gov. Gavin Newsom signed into law CSBA’s co-sponsored Senate Bill 1315, requiring the CDE to document and report to the Legislature the number of state and federally mandated reports LEAs must submit. The goal was to identify where information could be consolidated and which reports could be eliminated — helping schools free more time and resources to provide for the needs of students. Unfortunately, the CDE only completed the identifying requirements portion of the bill and did not make the concrete recommendations sought to address the reporting overload.

“It’s been an iterative approach,” said CSBA’s Merwin. “We started with SB 1315 and a big component of that bill was requiring the CDE to develop a list of reports and identify within that list what’s duplicative, what can be truncated and what’s so obsolete it can be just eliminated entirely. And unfortunately, that was due in March of last year and the report the CDE produced did not really answer the fundamental question of where it’s possible to make things easier for LEAs.”

With this legislative session, CSBA has introduced new bills that look to the future of how reporting requirements will be implemented, and take another swing at trying to identify reports that can be combined, truncated or eliminated. CSBA saw its first success of the year with the adoption of House Resolution 87 (Muratsuchi, D-Torrance), co-sponsored with the California Association of School Business Officials (CASBO) and the Association of California School Administrators (ACSA). HR 87 urges the Governor and Legislature to analyze questions of purpose, audience, value, feasibility, duplication and duration as part of the existing committee and floor bill analysis process when analyzing, considering, developing or implementing new reporting or planning requirements.

Also moving through the Legislature are CSBA’s Assembly Bill 2008 (Patel D-San Diego) and AB 2496 (Solache, Jr., D-Lynwood). AB 2008, co-sponsored with CASBO, ACSA and the Small School Districts Association, would require the CDE, on or before Oct. 1, 2027, “to release a standardized template for use by school districts, county offices of education, and charter schools when completing programmatic or expenditure reports” in consultation with LEAs. It would also require, beginning Jan. 1, 2028, that newly created reporting requirements sunset after four years.

AB 2496, co-sponsored with ACSA and CASBO, would start the process of repealing the School Accountability Report Card (SARC), which duplicates much of the information available on the California School Dashboard and other CDE resources. This begins with taking inventory of all of the SARC requirements and identifying what can already be found on the Dashboard or another website managed by the CDE, what would need a new home, and what can be eliminated. It would also add flexibility to the currently rigid mandate to provide a mid-year update on the LCAP at a time of year that often conflicts with several other reporting actions.

“HR 87 and SB 2008 are forward-looking attempts at how we can keep the burden from getting worse,” Merwin said. “AB 2496 takes a different approach, and it looks at two things that we have heard frequently from our members, which is that they find there is duplication and not the greatest benefit in the SARC and the mid-year LCAP update.”

CSBA’s Drowning in Documentation report made a series of recommendations to ease the burden of reporting requirements in order to free up administrator time to focus on instructional programs and other student supports. These recommendations ask the state to step up in supporting LEAs with the reporting burden — an echo of CSBA’s Close the State Accountability Gap campaign and legislation, which you can read more about in this issue’s cover story.

1. Recommit to the logic of LCFF by:
   • Reconsidering the use of categorical programs outside of the LCFF model.
   • Committing to a three-year goal of significantly reducing the number of data elements in the LCAP.
2. Reduce the reporting load by:
   • Conducting a comprehensive review of current requirements, aiming to reduce LEA 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, waiving certain requirements for districts with an enrollment under 1,000 students and developing shorter formats for small districts.
3. Increase support for LEAs by:
   • Shifting the data compilation burden to higher levels (county, state) and allowing greater investments in staffing and/or technology.
   • Investing in better tools and technology such as advanced programming that can assimilate data elements from various sources and forms. Additionally, develop portals that pre-populate with existing district data and provide drop-down options for short responses.
   • Developing sample content for required plans that LEAs can adapt or adopt.
   • Enabling very small districts to choose an intermediary, such as county offices of education or regional hubs, to write plans and reports on their behalf.
   • Providing guidance for using artificial intelligence to generate content at the district level and gain insights from data at the state level.
4. Develop better feedback loops between the state and LEAs by:
   • Establishing standing advisory groups that provide opportunities for end-users to weigh in on existing requirements and future changes.
   • Regularly analyzing State Board of Education waiver requests to identify common challenges and potential statutory fixes.

CSBA continues to advocate for LEAs with the state and is currently developing a review of the LCAP to provide feedback on particular pain points LEAs experience and recommendations on how they can be addressed. “Those changes might not appear in the next template because of the need for statutory changes,” said CSBA’s Briggs. “However, we hope to develop a roadmap for what statutory changes we can request to make a future update possible. For the LCAP and other reports, one important component for legislators is the ability to look at the whole system, think about what’s manageable at the local level and consider what the impact on LEAs is going to be.”