BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1892
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          Date of Hearing:   April 30, 2014

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Joan Buchanan, Chair
                  AB 1892 (Bocanegra) - As Amended:  March 17, 2014
           
          SUBJECT  :   School accountability:  local control and  
          accountability plans:  English learner pupils

           SUMMARY  :   Adds pupils redesignated as fluent English proficient  
          to the list of "unduplicated pupils" for purposes of the Local  
          Control Funding Formula (LCFF) and makes related changes.   
          Specifically,  this bill  :

          1)Adds redesignated English learners (ELs) to English learners,  
            low income pupils, and foster youth for purposes of generating  
            supplemental grant and concentration factor funding under LCFF  
            for school districts, county offices of education, and charter  
            schools.

          2)Provides that redesignated ELs shall generate supplemental  
            grant and concentration factor funding for two consecutive  
            years after the pupil has been redesignated as a fluent  
            English learner.

          3)Provides that redesignated ELs who fall into more than one  
            unduplicated pupil category shall count only once for funding  
            purposes.

          4)Requires that, as a condition of receiving supplemental and  
            concentration grant funds, school districts and county offices  
            of education shall identify any specialized programs or  
            services provided to pupils redesignated as fluent English  
            proficient in order for them to maintain proficiency in  
            English and access the common core academic content standards  
            and a broad course of study, as specified.

           EXISTING LAW  establishes the LCFF, which provides funding to  
          local education agencies (LEAs) in three parts:

          1)A base grant, which is the same amount per ADA for all  
            districts and varies according to four grade spans.

          2)A supplemental grant, which is equal to 20% of the base grant,  
            and is provided for each pupil who is identified as either low  








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            income (LI), as determined by eligibility for free or  
            reduced-price meals, an English learner (EL), or in foster  
            care.

          3)A concentration factor, which provides an additional 50% of  
            the base grant for each pupil who is eligible for the  
            supplemental grant and who is in excess of 55% of the  
            district's or charter school's enrollment (in other words,  
            those pupils generate the 20% supplemental grant plus the 50%  
            concentration factor, for an additional 70% of the base  
            grant).

          The formula uses an "unduplicated count," which means that  
          pupils who fall into more than one category are counted only  
          once.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :    This bill  expands the number of unduplicated pupils  
          by adding ELs who have been redesignated as fluent English  
          proficient for two years.  It is not known at this time how many  
          pupils this will add to the unduplicated count, but not all  
          redesignated pupils will add to the count, because many of them  
          will already be counted as low income.  To the extent that this  
          change increases the LCFF target level of funding for districts,  
          it will increase the statewide cost of fully funding the  
          formula.  This, in turn, will increase the number of years it  
          would otherwise take to fully fund the LCFF.

           Reason for the bill.   This bill is predicated on two  
          assumptions:  one, that EL pupils need continued support after  
          redesignation to ensure continued academic success; and, two,  
          that the loss of additional funding for EL pupils after they are  
          redesignated provides a disincentive to redesignate and  
          unnecessarily holds pupil back.
           
          Redesignated EL pupils perform well  .  A 2014 report by the  
          Public Policy Institute of California ("Redesignation of English  
          Learner Students in California"') states that "[redesignated]  
          students achieve much better academic outcomes than EL students,  
          even after controlling for some systematic differences in  
          student and district characteristics."  What's more,  
          "[redesignated] students, regardless of when they were  
          redesignated, are the most successful students in terms of  
          on-time (or better) grade progression to 12th grade," and  








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          "[redesignated] students perform better than [English only]  
          students in many cases."  This may call into question the need  
          for automatically providing additional funding for all  
          redesignated students, most of whom apparently don't need the  
          additional support the funding provides.  

           But the redesignation bar may be set too high.   An alternative  
          explanation for the apparent success of redesignated pupils may  
          be that districts set the bar too high when determining whether  
          to redesignate.  There is no statewide standard for  
          redesignating EL pupils, and as a result districts apply  
          different criteria.  The State Board of Education (SBE) has  
          adopted minimum guidelines for districts to use in the  
          redesignation of English learners, consistent with the current  
          requirement in law that the criteria be based on specified  
          multiple criteria, but ultimately each district sets  its own  
          cut scores and redesignation requirements, including local  
          criteria.  The SBE guidelines for redesignation are as follows:   


          1)Pupil scores at the early advanced or higher level overall on  
            the CELDT and scores at intermediate or higher in listening  
            and speaking, reading, and writing.

          2)Pupil scores in the range between the beginning of basic and  
            midpoint of basic on the English language arts (ELA)  
            California Standardized Test (CST), but it is up to each  
            district to set an exact cut point.

          3)Pupils meet the academic performance indicators set by the  
            school district as determined by the teacher evaluation.

          4)Parent is notified of his or her right and encouraged to  
            participate in the redesignation process, including through a  
            face-to-face meeting.

          A 2005 report by the California State Auditor found wide  
          inconsistencies among districts in how these minimum standards  
          are applied, and some districts set the bar higher than others.   
          The report recommended that the CDE seek legislation to achieve  
          greater consistency among districts in determining when to  
          redesignate English learners.  
           
          The redesignation dilemma  :  In determining when the appropriate  
          time is to redesignate ELs, two issues emerge.  One is the  








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          potentially premature redesignation of ELs which could result in  
          the loss of instructional services and supports before they are  
          ready, and this could eventually lead to greater risk of  
          educational failure.  The second issue is the possibility of  
          holding ELs back from redesignation longer than necessary, which  
          may result in ELs experiencing reduced access to courses needed  
          for postsecondary education.  Some have suggested that the LCFF  
          may provide a disincentive redesignate when appropriate and  
          beneficial, because it would reduce the number of pupils who  
          qualify the LEA for supplemental grant and concentration factor  
          funding.  One purpose of  this bill  is to reduce that  
          disincentive.

          The report, Effects of the Implementation of Proposition 227 on  
          the Education of English Learners, K-12, which was prepared by  
          WestEd in 2006, reviewed the redesignation policies and  
          practices of nine school districts in California to identify how  
          local and state policies and practices contribute to different  
          EL outcomes.  The report notes that current state guidelines on  
          criteria and cut-scores generate confusion and ambiguity about  
          the meaning of redesignation.  The report also notes that there  
          are various perceptions in the field regarding the significance  
          of redesignation.  Some districts view it as ELs reaching  
          "minimum competency" to participate in mainstream classrooms  
          with no further specialized services.  For other districts,  
          redesignation means that there is comparability between ELs and  
          native English speakers' academic performance in the district.   
          In other instances it is viewed as ELs having recouped the  
          "academic deficits" that ELs incur while developing English  
          language skills.  Lastly, some believe that redesignation  
          demonstrates English learners' ability to meet grade-level  
          standards and to be academically successful.  In consideration  
          of these issues, the report points out, "Virtually all of our  
          sample districts expressed support for establishing consistent  
          cut scores statewide on California's two common criteria.  At  
          the same time, these educators also expressed concern that the  
          state may set these criteria too low, or decide to eliminate the  
          use of local assessments, which districts highly value as a  
          source of 'multiple measures' to increase confidence in their  
          decisions to redesignate."   

           Local decision making may be a factor  .  It has been argued that  
          setting the bar too high holds EL pupils back by denying them  
          access to higher-level academic courses.  But this may be more a  
          function of administrative decision making at the school and  








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          district levels than a function of the EL designation.  The 2005  
          auditor's report found that some pupils who scored well on the  
          CELDT were denied redesignation on the basis of one or more of  
          the other criteria.  (In fact, 112 of 180 EL pupils reviewed  
          were not redesignated even after meeting  all  of the district's  
          criteria.)  If a student's CELDT score indicates that she could  
          benefit from a higher-level academic course, there is nothing to  
          prevent districts from allowing her to enroll in that course,  
          even if she is still designated EL.  
           
          CALPADS issues.   The California Longitudinal Pupil Achievement  
          Data System (CALPADS) is the statewide data base that tracks  
          pupil data.  The data in CALPADS are used to calculate each  
          LEA's funding under the LCFF.  According to the California  
          Department of Education (CDE), CALPADS already tracks  
          redesignated ELs.  However, the system would have to be modified  
          to track pupils who have been redesignated for two years.

          In addition, CDE reports issues with data quality.  For example,  
          some pupils have gone back and forth from EL to redesignated,  
          even though they're not supposed to.  (This can happen when  
          pupils move between districts, which is another argument for  
          standard statewide standards.)  The CDE has recently adopted  
          procedures to validate the data they get from LEAs, but they may  
          need statutory authority to implement stronger procedures to  
          ensure the accuracy of data used for funding purposes.  The  
          department reports that these changes cannot be done by the fall  
          of 2014, and that making them would require additional resources  
          and a reprioritization of existing projects.

           Alternative solution  .  According to the author's office, "the  
          rates of redesignation very greatly across districts," and more  
          than 90% of districts report using criteria that are more  
          demanding than those suggested by the SBE.  It is argued that  
          this bill will encourage districts to be less conservative in  
          their redesignation decision-making, because they "won't have  
          the threat of losing precious supplemental funding dollars."   
          Basically, school districts have created a problem by being too  
          conservative in their application of redesignation criteria, and  
          now they argue that additional funding is needed to change their  
          behavior.  However, the solution contained in this bill would  
          result in all redesignated pupils receiving supplemental grant  
          and possibly concentration factor funding, even though the PPIC  
          report suggests that large numbers of them do not need the  
          services those dollars support. In addition, there is no  








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          guarantee that this bill actually would change local decision  
          making, because districts could still use their existing  
          redesignation criteria and then benefit from an another two  
          years of additional funding beyond that.  To the extent this  
          truly is a redisignation problem, a more direct approach would  
          be to establish statewide redesignation criteria that all  
          districts would have to follow.  

          Finally, if the problem is that districts do not give EL pupils  
          access to the full curriculum until they are redesignated, that  
          is a local decision-making issue that would not necessarily be  
          changed by this bill.  Supporters of the bill have acknowledged  
          that some districts have denied access to some courses even to  
          EL pupils who have scored high on the CELDT for two or more  
          years, simply because those pupils did not meet the district's  
          other criteria for redesignation.  Such decisions are not a  
          requirement of existing law and may be in conflict with existing  
          law.  Many districts provide full access to a-g courses for  
          English language learners.  There is no evidence that providing  
          additional funding after redesignation would change the  
          course-placement decisions that districts make prior to  
          redesignation.

          For these reasons, staff recommends that the bill be amended to  
          delete its current contents and instead require the CDE to  
          report to the Legislature by January 1, 2016 with  
          recommendations for establishing statewide standards and  
          criteria for the redesignation of EL pupils.  This requirement  
          would be added to Education Code Section 313.5, which already  
          requires the CDE to review and analyze the criteria, policies,  
          and practices that a representative sample of school districts  
          use to redesignate EL pupils and to recommend best practices to  
          the Legislature and SBE by January 1, 2014.
           
          Related legislation  .  SB 1108 (Padilla), which is pending in the  
          Senate, extends the deadline for the CDE to recommend best  
          practices to the Legislature by January 1, 2016.  However, the  
          recommended standards and criteria provided by the CDE already  
          constitute best practices, and districts are choosing to exceed  
          them.  The recommended amendment for this bill would instead  
          require recommendations for statewide standards and criteria  
          that all districts would use.
           
          Arguments in support.   Supporters argue that the change in  
          status, itself, has important consequences for pupils and that  








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          it is needed to allow former EL pupils access to "mainstream  
          academic programs."  Allowing districts to retain EL funding for  
          pupils for two years after redesignation will remove the  
          disincentive to redesignate when it is academically appropriate  
          and provide funding for needed follow up support services.
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Association of California School Administrators
          California Association for Bilingual Education
          California Association of Latino Superintendents
          California Communities United Institute
          California Immigrant Policy Center
          California School Boards Association
          Californians Together
          Central Valley Education Coalition
          Education Trust-West
          Los Angeles Unified School District
          Public Counsel
          Riverside County Superintendent of Schools
          San Diego Unified School District

           Opposition 
           
          None received
           
          Analysis Prepared by  :    Rick Pratt / ED. / (916) 319-2087