BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 1473
                                                                  Page  1

          Date of Hearing:   June 16, 2010

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                    SB 1473 (Wyland) - As Amended:  April 28, 2010

           SENATE VOTE  :   34-0
           
          SUBJECT  :  School facilities bond proceeds:  performance audits

           SUMMARY  :  Requires the annual, independent performance audit  
          required by Proposition 39 of 2000 to be conducted in accordance  
          with the Government Auditing Standards issued by the Comptroller  
          General of the United States.  

           EXISTING LAW  :

          1)Authorizes, under Section 1 of Article XIII A of the  
            California Constitution, school districts, community college  
            districts, or county offices of education to pass a general  
            obligation bond by a 55% vote, provided that the local  
            initiative includes the following accountability measures:

             a)   A requirement that the proceeds from the sale of the  
               bonds be used only for the construction, reconstruction,  
               rehabilitation, or replacement of school facilities,  
               including the furnishing and equipping of school  
               facilities, or the acquisition or lease of real property  
               for school facilities, and not for any other purpose;

             b)   Provide a list of the specific school facilities  
               projects to be funded and certification that the school  
               district board, community college board, or county office  
               of education has evaluated safety, class size reduction,  
               and information technology needs in developing that list;

             c)   A requirement that the school district board, community  
               college board, or county office of education conduct an  
               annual, independent performance audit to ensure that the  
               funds have been expended only on the specified projects;  
               and,

             d)   A requirement that the school district board, community  
               college board, or county office of education conduct an  
               annual, independent financial audit of the proceeds from  








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               the sale of the bonds until all of those proceeds have been  
               expended for the school facilities projects.

          2)Authorizes school districts, community college districts, and  
            county offices of education to levy a 55% vote ad valorem tax  
            pursuant to limits specified in the proposition.

          3)Requires the governing board of a school district or a  
            community college district to establish and appoint members to  
            an independent citizens' oversight committee within 60 days of  
            the date that the governing board enters the election results  
            on its minutes.  

          4)Requires each county superintendent of schools to provide for  
            an audit of all funds under his or her jurisdiction and  
            control.  Requires governing board of each local educational  
            agency (LEA) to either provide for an audit of the books and  
            accounts of the LEA or make arrangements with the county  
            superintendent of schools to provide for that auditing.   
            Requires the audit to comply fully with the Government  
            Auditing Standards issued by the Comptroller General of the  
            United States.

           FISCAL EFFECT  :  According to the Legislative Counsel, this bill  
          is nonfiscal.

           COMMENTS  :   Background  .  Proposition 39 was passed by voters in  
          2000.  Among others, the Proposition, a Constitutional  
          Amendment, reduced the voting threshold for the passage of local  
          general obligations bonds from two-thirds to 55% provided that  
          the local bond initiative meets the following accountability  
          measures:

          1)The initiative identifies a list of the specific school  
            facilities projects that will be funded by bond proceeds; 

          2)A requirement that the school board, community college board,  
            or county office of education conduct an annual, independent  
            performance audit to "ensure that the funds have been expended  
            only on the specific projects listed;" and,

          3)A requirement that the school board, community college board,  
            or county office of education conduct an annual, independent  
            financial audit of the proceeds from the sale of the bonds  
            until all of those proceeds have been expended for the school  








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            facilities projects.

          Both the financial audit and performance audit must be reviewed  
          by an independent citizens' oversight committee.  AB 1908  
          (Lempert), Chapter 44, Statutes of 2000, a companion bill to  
          Proposition 39, requires each district, within 60 days of the  
          passage of a local bond with 55% to appoint a citizens'  
          oversight committee to monitor and review expenditures to ensure  
          compliance with Proposition 39 requirements, and to keep the  
          public informed about bond expenditures.  

          According to the author, school districts and their local bond  
          oversight committees are confused with regard to the standard to  
          follow in carrying out the mandatory performance audit, since  
          existing law does not specify an accounting standard.   
          Currently, some districts have one auditor conduct both the  
          financial and performance audits, others commission for  
          extensive audits that review multiple aspects of a district's  
          facilities program, and some are presenting the financial audit  
          as both the financial and performance audits.  Supporters of the  
          bill argue that conducting one audit that counts as both a  
          financial and performance audit does not comply with Proposition  
          39 requirements and does not provide the accountability the  
          initiative intended.    

          This bill requires the performance audit to be conducted in  
          accordance with the generally accepted government auditing  
          standards (GAGAS), informally known as the "Yellow Book", issued  
          by the comptroller general of the United States (U.S.), who  
          heads the U.S. Government Accountability Office (GAO).  The  
          GAGAS contains standards for audits of government organizations,  
          programs, activities, and functions, and of government  
          assistance received by contractors, nonprofit organizations, and  
          other nongovernment organizations.  The standards pertain to  
          auditors' professional qualifications and outline the processes  
          and parameters to achieve quality audits.  
                                                                            
                                                                            
                                                              
           Performance Audit  .  According to the GAO, "Performance audits  
          entail an objective and systematic examination of evidence to  
          provide an independent assessment of the performance and  
          management of a program against objective criteria?."  

          The GAGAS outlines several types of performance audits that  








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          serve different objectives, including the following:

          1)Program effectiveness and results audits are frequently  
            interrelated with economy and efficiency objectives.  Program  
            effectiveness and results determine the extent to which the  
            intended results or benefits are being achieved, the  
            effectiveness of the entity, program, activity or function,  
            and whether the entity has complied with law and regulations  
            applicable to the program.  Economy and efficiency objective  
            addresses the costs and resources used to achieve program  
            results;

          2)Internal control audits relate to an assessment of the  
            component of an organization's system of internal control that  
            is designed to provide reasonable assurance of achieving  
            effective and efficient operations, reliable financial and  
            performance reporting, or compliance with applicable laws and  
            regulations; 

          3)Compliance audits relate to compliance criteria established by  
            laws, regulations, contract provisions, grant agreements, and  
            other requirements that could affect the acquisition,  
            protection, use, and disposition of the entity's resources and  
            the quantity, quality, timeliness, and cost of services the  
            entity produces and delivers; and, 

          4)Prospective analysis audit objectives provide analysis or  
            conclusions, about information that is based on assumptions  
            about events that may occur in the future along with possible  
            actions that the audited entity may take in response to the  
            future events.

          The GAGAS performance audit standards described above may  
          require a more extensive evaluation of local bond funds than  
          that required by Proposition 39.  Proposition 39 simply requires  
          a performance audit to ensure that funds were spent only on the  
          projects for which the ballot initiative indicated the funds  
          would be used.  As such, the GAGAS standard for compliance audit  
          appears to be most consistent with the Proposition 39  
          requirement.  Staff recommends clarifying that the GAGAS  
          standard used to perform Proposition 39 performance audit shall  
          be consistent with Proposition 39 objective to ensure that funds  
          are spent only on the projects for which the ballot initiative  
          indicated the funds would be used.  









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          Should the GAGAS standard be applied to the financial audit too?  
           According to the California Association of School Business  
          Officials, school districts are already conducting the  
          Proposition 39 financial audits using the GAGAS standards when  
          done in conjunction with the annual financial audit required  
          through EC 41020.  However, to ensure that there is no  
          misinterpretation that because this bill only addresses the  
          performance audit that the Legislature then does not intend to  
          apply the GAGAS standards to financial audits, staff recommends  
          applying the GAGAS standards to both the financial and  
          performance audits.  

          Staff recommends a technical amendment to change the placement  
          of this provision in the Education Code.  The bill proposes to  
          insert the requirement in the section related to citizens'  
          oversight committees in Article 2 of Chapter 1.5.  Staff  
          recommends relocating the provision to Article 3 of Chapter 1.5  
          relating to bond accountability.  

           Arguments in Support  .  The Board of Governors of the California  
          Community Colleges states that "without specifying GAGAS in law,  
          quite a few K-14 districts have resorted to using 'attestation'  
          or 'agreed upon procedures' agreements with their audit firms to  
          do their performance audits with varying success.  In some  
          highly publicized cases, these 'agreed upon procedures'  
          agreements have resulted in a decided lack of oversight of  
          Proposition 39 local bonds.  By specifying the use of GAGAS,  
          these types of agreements will no longer be allowed.  SB 1473  
          would establish a more reasonable standard that would address  
          the concerns of taxpayer associations without adding onerous  
          requirements."

           Previous related bill  :  AB 125 (Ma), vetoed by the Governor in  
          2007, would have authorized the independent performance audit  
          required by Proposition 39 to include reviews of the compliance  
          by a school district or a community college district with its  
          bond ballot language, design and construction costs and  
          schedules, design and construction budgets, program and  
          construction management costs, construction change orders, claim  
          procedures and results, payment procedures, and bidding and  
          procurement procedures.  The Governor's veto message stated that  
          the bill was unnecessary and that there was nothing to prohibit  
          a school district from including the proposed elements in the  
          audits.









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           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Association of School Business Officials
          Board of Governors of the California Community Colleges
          Howard Jarvis Taxpayers Association
           
            Opposition 
           
          None on file

           Analysis Prepared by  :    Sophia Kwong Kim / ED. / (916) 319-2087