BILL ANALYSIS                                                                                                                                                                                                    




                   Senate Appropriations Committee Fiscal Summary
                           Senator Christine Kehoe, Chair

                                           2266 (Bradford)
          
          Hearing Date:  08/12/2010           Amended: 08/04/2010
          Consultant:  Dan Troy           Policy Vote: ED 7-0
          _________________________________________________________________ 
          ____
          BILL SUMMARY:   AB 2266 would modify requirements for the  
          maintenance and destruction of original school district  
          documents.  
          _________________________________________________________________ 
          ____
                            Fiscal Impact (in thousands)

           Major Provisions         2010-11      2011-12       2012-13     Fund
           Audit findings         Potential loss of savings, potentially  
          General*
                                 in the millions                  
                                            
          * Counts toward meeting the Proposition 98 minimum funding  
          guarantee
          _________________________________________________________________ 
          ____

          STAFF COMMENTS: SUSPENSE FILE.  

          Current law allows the governing board of a school district to  
          make photographic, microfilm, or electronic copies of records,  
          as specified.  Current law allows for the destruction of  
          original records if they have been copied and are permanently  
          maintained, except that no original document that is basic to a  
          required audit may be destroyed prior to the beginning of the  
          second fiscal year succeeding the completion of the audit.  

          As of January 1, 2013, this bill would eliminate the requirement  
          to retain original documents required for an audit for any time  
          period, as long as they can be reproduced in a photographic,  
          microfilm, or electronic form through a "trusted system," as  
          defined in the Government Code.  Essentially, reproductions of  
          the original documents could replace original documents for  
          purposes of audit reviews if the copies are nonalterable.  

          While it may be possible to utilize trusted systems that ensure  
          copies of original documents are not altered, allowing the  










          destruction of original documentation prior to the completion of  
          required audits may compromise the audit integrity.  Auditors  
          require access to original documentation in order to assure the  
          accuracy and integrity of contemporaneous record keeping.   
          Statewide summary information available from the SCO for the  
          2008-09 fiscal year indicate that there were 136 audit findings  
          regarding attendance accounting requirements that year, 46  
          findings regarding independent study, and 19 findings concerning  
          instructional time requirements, among many other findings.   
          While determining the ultimate cost of all of these findings is  
          difficult due to the appeals process and negotiated payment  
          plans, loosening the laws requiring the maintenance of original  
          documentation may make it difficult for auditors to determine  
          when districts have inappropriately claimed state funding.   
          Given that one unit of average daily attendance is worth over  
          $5,000 in funding, the potential loss to the state could be in  
          the millions on an annual basis.  

          Page 2
          AB 2266 (Bradford)

          Further, according to the State Controller's Office, current  
          government auditing standards require review of original  
          documentation. To the extent auditors are not able to issue  
          unqualified audit opinions as to the accuracy of the  
          information, districts may not be able to receive funding for  
          federal or state programs.  If verification requires more  
          investigation on the part of the auditor, the costs borne by the  
          districts for the audit could increase.  This may offset savings  
          on storage costs that districts might hope to achieve.