BILL ANALYSIS                                                                                                                                                                                                    �






                         SENATE COMMITTEE ON EDUCATION
                                Carol Liu, Chair
                           2013-2014 Regular Session
                                        

          BILL NO:       AB 1199
          AUTHOR:        Fong
          AMENDED:       May 24, 2013
          FISCAL COMM:   Yes            HEARING DATE:  July 3, 2013
          URGENCY:       Yes            CONSULTANT:  Daniel Alvarez

           SUBJECT  :  Community colleges: funding.
          
           SUMMARY  

          This bill, an urgency measure, essentially establishes a  
          loan program for community colleges under specified  
          accreditation sanctions. This bill requires the Board of  
          Governors (BOG) of the California Community Colleges (CCC)  
          to adopt a revenue funding formula that provides CCC  
          districts under specified accreditation status (probation  
          or "show cause"), a second year of declining enrollment  
          revenue relief, provided certain conditions are met, and  
          the district must pay back the second year of declining  
          enrollment revenue in equal installments over the following  
          two years.

           BACKGROUND  

          Existing law confers upon the Board of Governors of the  
          California Community Colleges the ability to prescribe  
          minimum standards for the formation and operation of  
          community colleges and exercise general supervision over  
          the community colleges (Education Code � 66700 and �  
          70901).  As such, regulations have been adopted to require  
          each community college within a district to be an  
          accredited institution - with the Accrediting Commission  
          for Community and Junior Colleges (ACCJC) determining  
          accreditation.  After an initial accreditation, colleges  
          must have their accreditation reaffirmed every six years.  
          This process includes a self-study, a site visit by a team  
          of peers, a recommendation by the visiting team, and an  
          action by the ACCJC.

          Existing law requires the BOG to develop criteria and  
          standards, in accordance with specified statewide minimum  







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          requirements, for the purposes of making the annual budget  
          request for the CCC to the Governor and the Legislature and  
          allocating state general apportionment revenues, among  
          other things, a requirement that the calculations of each  
          district's revenue level for each fiscal year be based on  
          specified criteria with revenue adjustments being made for  
          increases or decreases in full-time equivalent students  
          (FTES) for specified purposes. 

          Existing law provides a year of stabilization funding,  
          during which the district receives at least the same  
          funding for enrollment as the previous year (even if  
          enrollment declines) or higher funding (up to an allowable  
          cap) if enrollment increases. This is because a district  
          usually does not know that its full-time equivalent student  
          (FTES) count has declined until it begins its enrollment  
          counts, which occur at the same time the state is  
          disbursing funds and after the district has hired faculty  
          and determined its class schedules.  If enrollment declines  
          beyond just one year, the district's revenues are reduced  
          by the decrease in its FTES.  However, those reductions are  
          restored if enrollments increase during the subsequent  
          three years, providing a district with a buffer against  
          fluctuating enrollments. (Education Code � 84750.5 et.seq.)

           ANALYSIS
          
           This bill  , an urgency measure, essentially establishes a  
          loan program for community colleges under specified  
          accreditation sanctions.  This bill requires the Board of  
          Governors (BOG) of the California Community Colleges (CCC)  
          to adopt a revenue funding formula that provides CCC  
          districts under specified accreditation status (probation  
          or "show cause"), a second year of revenue relief from  
          declining enrollment, provided certain conditions are met  
          by the district, and that must be paid back in equal  
          installments over the following two years.  More  
          specifically, this bill:

          1)   Requires the BOG to adopt the formula for determining  
               revenue adjustments to district's fiscal-year revenue  
               levels if all of the following conditions are met:

               a)        The district or campus of the district is  








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                    subject to probation or a "show cause"  
                    accreditation sanction.

               b)        The district has identified a new funding  
                    source sufficient for the full payment of any  
                    fund liability in equal installments over the  
                    next two years.

               c)        The district submits an improvement plan to  
                    the CCC Chancellor that:

                    i)             Includes a six-month accreditation  
                         compliance report that details the  
                         district's to-date progress, signed by the  
                         district chancellor and passed by the  
                         district's board of trustees.

                    ii)            Includes a timetable to complete a  
                         full and satisfactory accreditation  
                         response.

          1)   Requires the stabilization formula per (1) to provide  
               the following adjustments in district revenues for a  
               qualifying district experiencing decreases in  
               full-time equivalent students (FTES): 

               a)        Decreases in FTES shall result in revenue  
                    reductions beginning in the year following the  
                    initial year in which the district qualifies for  
                    this stabilization funding. This provides a  
                    second year of revenue relief from declining  
                    enrollment for qualifying colleges/districts.

               b)        Revenue reductions in the second and third  
                    years after the district qualifies for the  
                    stabilization funding shall include payments by  
                    the district of equal installments in each of  
                    these years to cover the difference between the  
                    stabilization funding the district would have  
                    received pursuant to existing law and what the  
                    district did receive pursuant to (2)(a).
           
          STAFF COMMENTS  









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           1)   According to the author,  "this bill is necessary to  
               assist community colleges under severe sanction from  
               an accreditation agency that are also forecasting  
               current year enrollment reduction.  This bill will  
               provide a stabilizing formula over a three-year period  
               in order to keep courses open for students and ensure  
               a high quality level of education by retaining  
               faculty.  

           2)   This bill establishes a loan program for community  
               colleges under specified accreditation sanctions  .  By  
               accepting a 2nd year of declining enrollment revenue  
               relief (loan) from the state, and since the additional  
               stabilizing funding must be paid back, doesn't this  
               change the underlying oversight, fiscal, and  
               management relationship between the state and the  
               college/district?  The college / district in this  
               instance is mandated to accept the 2nd year of  
               declining enrollment revenue (if the conditions on a  
               new source of revenue are met) which in term  
               acknowledges deficient financial, budgetary and/or  
               management oversight, shouldn't the state now have  
               more authority in the operations of a college /  
               district?  

               For example, existing law establishes, for K-12 school  
               districts, a process for state oversight and financial  
               assistance for schools in financial trouble, and  
               authorizes the governing board of a school district  
               that determines that its revenues are insufficient to  
               meet its current year obligations to request an  
               emergency apportionment (loan) from the state through  
               the Superintendent of Public Instruction.  An  
               emergency apportionment (loan) from the state results  
               in the state taking control of the school district.  
               The degree of state control is determined by the size  
               of the loan relative to the district's budget. 

           3)   Accreditation  is required to receive state  
               appropriations and to be eligible for federal and  
               state financial aid programs.  Accreditation is a  
               method used in this country to generally: (1) assure  
               quality, (2) provide access to government funding, (3)  
               generate stakeholder support, and (4) facilitate  








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               credit transfer for and to educational institutions.  
                
                After an initial accreditation, colleges must have  
               their accreditation reaffirmed every six years. This  
               process includes a self-study, a site visit by a team  
               of peers, a recommendation by the visiting team and an  
               action by the Accrediting Commission for Community and  
               Junior Colleges (ACCJC).  In addition to these core  
               components, colleges must submit a midterm report  
               every three years and annual progress reports. The  
               college/district may also have to submit follow-up  
               reports and host visits as required by the commission.  
                

               There are three levels of sanction prior to  
               termination of accreditation:  Warning, Probation, and  
               Show Cause.  Follow up reports and accreditation  
               visits are required to retain full accreditation.

               a)        Warning occurs when the accrediting  
                    commission finds that an institution has pursued  
                    a course deviating from the commission's  
                    eligibility requirements, accreditation  
                    standards, or commission policies to an extent  
                    that gives concern to the commission, it may  
                    issue a warning to the institution to correct its  
                    deficiencies, refrain from certain activities, or  
                    initiate certain activities. The accredited  
                    status of the institution continues during the  
                    warning period.

               b)        Probation occurs when an institution  
                    deviates significantly from the commission's  
                    eligibility requirements, accreditation  
                    standards, or commission policies, but not to  
                    such an extent as to warrant a Show Cause order  
                    or termination of accreditation, or fails to  
                    respond to conditions imposed by the commission,  
                    including a warning.  During the probation  
                    period, the institution will be subject to  
                    reports and visits at a frequency determined by  
                    the commission.  The accredited status of the  
                    institution continues during the probation  
                    period.








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               c)        Show Cause occurs when the commission finds  
                    an institution to be in substantial  
                    non-compliance with its eligibility requirements,  
                    accreditation standards, or commission policies,  
                    or when the institution has not responded to  
                    conditions imposed by the commission, the  
                    commission will require the institution to Show  
                    Cause why its accreditation should not be  
                    withdrawn at the end of a stated period by  
                    demonstrating that it has corrected the  
                    deficiencies noted by the commission.  In such  
                    cases, the burden of proof will rest on the  
                    institution to demonstrate why its accreditation  
                    should be continued. The commission will specify  
                    the time which the institution must resolve  
                    deficiencies. While under Show Cause order, the  
                    institution will be subject to reports and visits  
                    at a frequency to be determined by the  
                    commission.  The accredited status of the  
                    institution continues during the period of the  
                    Show Cause order. 

               Many California community colleges have faced various  
               levels of accreditation sanctions, including Show  
               Cause. With the exception of Compton College in 2004,  
               all have retained accreditation. As of March 2013, six  
               community colleges are on Probation status and two  
               community colleges are on Show Cause status-City  
               College of San Francisco and College of the Sequoias.   


               In addition, College of the Redwoods and Cuesta  
               College sufficiently addressed their identified  
               deficiencies and were removed from Show Cause in  
               January 2013.  

           4)   Is providing state loans to a college that is going  
               through a difficult accreditation process a good  
               policy?    This measure is intended to provide an  
               additional year (total of 2 years) of revenue relief  
               funding resulting from a colleges' declining  
               enrollment, basically through the use of a short-term  
               loan from the State of California, for community  








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               colleges that are subject to a probation or show cause  
               accreditation sanction - presumably in order to  
               "stabilize" the underpinnings of the  
               college/district's budget and to keep courses open for  
               students and retain faculty.  Current law provides one  
               year of hold harmless on revenues when enrollment  
               declines. 

               This bill would provide colleges and districts in  
               perilous accreditation status a revenue bonus if their  
               enrollments are in decline.  Further, as staff  
               understands, community colleges are generally provided  
               time to resolve deficiencies identified through the  
               accreditation review process. It is unfortunate, that  
               a college may suffer a loss of funding because  
               students decide to exercise their options of either  
               attending or changing colleges, irrespective of  
               whether the accredited status of their current  
               institution is unchanged.  Students are free to pursue  
               their course of study at any college they deem can  
               meet their educational goals in a timely and  
               reasonable way.
           
                It is an equally unfortunate after-effect that the  
               current and future students of these colleges are the  
               real victims of the mismanagement of the college's  
               fiscal resources; however, other colleges that may be  
               on the brink of encountering similar accreditation  
               circumstances have addressed the timely and painful  
               local decision-making necessary to lift them from  
               their unfortunate fiscal and management situation  
               while maintaining their educational programs and  
               resolving accreditation issues.  As previously  
               mentioned the College of the Redwoods and Cuesta  
               College sufficiently addressed their identified  
               deficiencies and were removed from Show Cause by the  
               Accrediting Commission for Community and Junior  
               Colleges (ACCJC).

               What message does the State send to other colleges in  
               good accreditation standing, that the state will  
               provide revenue relief only when they are in perilous  
               accreditation position?









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           5)   Even with additional funding, improved accreditation  
               status isn't assured  .  Though the bill may provide a  
               modicum of arguable short-term stability, the outcome  
               of a positive accreditation status is highly  
               uncertain.  
                
                What should the state expect for providing additional  
               revenue or should the state have no expectation of a  
               successful progression in accreditation? What happens  
               if a college moves from "show cause" to probation  
               status, do they continue to benefit from additional  
               revenue relief as prescribed in this measure?  

               This bill requires the college / district to provide a  
               copy of a signed report and a time table for a full  
               and satisfactory accreditation response to the  
               California Community Colleges (CCC) Chancellor's  
               Office, however informative, such a report may be this  
               action has no meaningful effect, since the  
               Chancellor's office does not have jurisdiction over  
               accreditation compliance. 

           6)   This bill would seem to require a locally elected  
               governing board to receive a loan (2nd year of revenue  
               relief) and spend locally generated revenues to repay  
               it.   Of the two districts currently under show cause  
               sanction, only the City College of San Francisco  
               (CCSF) has a new funding source that could be  
               applicable to this bill. Last November, San Francisco  
               approved a parcel tax to raise approximately $15  
               million per year for CCSF.  

               Because CCSF was operating in deficit, the district's  
               governing board is planning to use most of this  
               revenue to increase its operating reserve and address  
               other deficiencies noted by the accrediting body.   In  
               this case, would the 2012 parcel tax be considered "a  
               new funding source" as envisioned in this measure,  
               since the district has budgeted for the use of these  
               parcel taxes (revenues) in 2013-14? 

               Should locally elected boards be required to spend  
               local revenues to repay stabilization funding when  
               they may choose to use the funds to address other  








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               issues, such as accreditation deficiencies?  Perhaps  
               this bill should allow a district to request the  
               stabilization formula authorized under these  
               provisions rather than mandating it?  Is the state  
               imposing a form of management best left for local  
               governing bodies to determine?

           7)   According to the Assembly Appropriations Committee  .  
               The California Community Colleges Chancellor's Office  
               states that, based on current enrollment estimates,  
               the stabilization formula would result in an  
               additional allocation within Proposition 98 funds of  
               $5.4 million to CCSF for 2012-13, which would be  
               repaid  by the district over the following two fiscal  
               years.

               Further the Assembly Appropriations Committee states,  
               "It is not clear from the bill what constitutes a new  
               funding source, nor is it clear whether a district  
               under "show cause" with a new local funding available  
               would be eligible for or required to seek the  
               additional stabilization funding." 

           8)   City College of San Francisco  .  Last July 2012,  
               Accrediting Commission for Community and Junior  
               Colleges (ACCJC) identified numerous deficiencies at  
               CCSF and moved the district directly to the most  
               severe level of sanction-"Show Cause."  ACCJC  
               identified numerous deficiencies covering a range of  
               district operations.  The most substantive findings  
               focus on failures in the areas of fiscal planning,  
               fiscal integrity, governance and administration, as  
               well as failure to completely address eight  
               recommendations from a 2006 ACCJC evaluation team.   
               The CCSF Board of Trustees has taken numerous actions  
               and approved plans to address the identified  
               deficiencies; however, it has been a contentious  
               process with much opposition from local stakeholders.   
               Even with an urgency clause, this measure is unlikely  
               to go into effect before July 15, 2013.   According to  
               the Chancellor's Office of the CCC, a public decision  
               on CCSF accreditation status will be formally  
               announced in early July 2013.









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           9)   Other Issues unaddressed since the initial policy  
               hearing.
           
               a)        Recourse for failure to repay?  It is  
                    conceivable that a district under Show Cause  
                    could lose accreditation and cease to operate.   
                    How would the state recoup the funding?

               b)        Qualifying districts must identify a new  
                    funding source sufficient to address any "fund  
                    liability."  Fund liability is not defined, nor  
                    does the bill specify whom the district is  
                    repaying.  

           SUPPORT  

          California Federation of Teachers
          California Labor Federation
          California School Employees Association
          California Teachers Association

           OPPOSITION

           None on file.