BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2621
                                                                  Page  1


          ASSEMBLY THIRD READING
          AB 2621 (Hueso)
          As Amended  May 16, 2012
          Majority vote 

           EDUCATION           6-4                                         
           
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          |Ayes:|Brownley, Ammiano,        |     |                          |
          |     |Buchanan, Butler, Carter, |     |                          |
          |     |Williams                  |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Norby, Grove, Halderman,  |     |                          |
          |     |Wagner                    |     |                          |
          |     |                          |     |                          |
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           SUMMARY  :  Permits the Grossmont Union High School District and 
          the Sweetwater Union High School District to enter into a 
          revenue-sharing agreement between their school cafeterias and 
          their associated student body organizations.  Specifically,  this 
          bill  :  

          1)Permits the above-named districts to allow as an expenditure 
            from their respective cafeteria funds or accounts a portion of 
            any funds that accrue from the joint sale of items involving a 
            school cafeteria and an associated student body student store 
            that is determined pursuant to an agreement entered into 
            between the school cafeteria and the associated student body 
            organization of that school.

          2)Requires any such agreement to meet all of the following 
            requirements:

             a)   The term of the agreement shall be for a period not to 
               exceed five years;

             b)   The agreement shall be effective only if the school 
               district has obtained the prior written approval from the 
               exclusive employee representative of the classified 
               employees in food service or cafeteria positions; and,

             c)   The participation of pupils, either as employees or 
               volunteers under the agreement, shall not result in the 








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               displacement of any classified employees, in a failure to 
               fill new classified positions, or in a failure to fill 
               vacancies that may occur in existing classified positions. 

          3)Defines "displacement" to include, but not be limited to, 
            layoff, demotion, reduction in work hours or work year, or 
            transfer to another classification or site.

           EXISTING LAW  :

          1)Allows a school district with more than 100,000 average daily 
            attendance to enter into an agreement with its associated 
            student body to share revenues generated by the joint sale of 
            items between the cafeteria and an associated student body 
            student store (Education Code Section 38092).

          2)Provides that the cafeteria fund shall be used only for those 
            expenditures authorized by the governing board as necessary 
            for the operation of school cafeterias, including, but not 
            limited to, expenditures for the lease or purchase of 
            additional cafeteria equipment for the central food processing 
            plant, vending machines and their installation and housing, 
            and computer equipment and related software (Education Code 
            Section 38091).

          3)Provides that revenues received by the school food service 
            shall be used only for the operation or improvement of the 
            food service and that expenditures of school food service 
            revenues shall be in accordance with the financial management 
            system established by the state agency (Code of Federal 
            Regulations, Title 7, Part 210.14(a)).

           FISCAL EFFECT  :  This bill is keyed non-fiscal by the Legislative 
          Counsel.

           COMMENTS  :  This bill is sponsored by the Sweetwater Union High 
          School District (SUHSD), which established a revenue-sharing 
          agreement between its cafeteria and its Associated Student Body 
          (ASB) organization in 2010-11.  Pursuant to that agreement, 
          student volunteers staffed food stations, filled meal orders, 
          and served as cashiers for the food service.  In exchange, a 
          portion of food service revenues were transferred to the ASB 
          organization.  The district reports that this arrangement 
          increased food service sales, provided job training for 








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          students, and provided additional revenue for the ASB 
          organization.

          However, an audit by the California Department of Education 
          (CDE) found this agreement to be in violation of state law and 
          federal regulations.  The CDE audit report, dated February 21, 
          2012, found the transfer of funds to the ASB organization to be 
          an expenditure that is "not reasonable or necessary for the 
          maintenance of the nonprofit food service" as required by state 
          law and violated the federal requirement that food service 
          revenues be used only for the operation of the food service.  
          The CDE ordered that $316,068 be returned to the district's 
          cafeteria fund from the ASB organization.  

          The SUHSD disagrees with the CDE's interpretation of federal 
          regulations.  At the district's request, U.S. Representative Bob 
          Filner has addressed a letter to the U.S. Department of 
          Agriculture (USDA) seeking clarification.  The letter asks the 
          following questions:

          1)Does the USDA agree that the MOUs between the Sweetwater 
            District's food services department and ASB organization 
            violated federal regulations and laws governing the financial 
            management of the nonprofit food service Cafeteria Account?

          2)In order to make such ASB/Cafeteria partnerships allowable is 
            it necessary to amend the Code of Federal Regulations?

          Because these questions are still unanswered, committee 
          amendments clarify that the authority established by this bill 
          applies "to the extent permitted by federal law."
           
           
           Analysis Prepared by  :    Rick Pratt / ED. / (916) 319-2087 


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