BILL ANALYSIS                                                                                                                                                                                                    �






                         SENATE COMMITTEE ON EDUCATION
                             Alan Lowenthal, Chair
                           2011-2012 Regular Session
                                        

          BILL NO:       SB 268
          AUTHOR:        Wright
          INTRODUCED:    February 14, 2011
          FISCAL COMM:   Yes            HEARING DATE:  March 30, 2011
          URGENCY:       No             CONSULTANT:Daniel Alvarez

           SUBJECT  :  Interdistrict pupil attendance and appeal.
          
           SUMMARY  

          This bill (1) specifies the scope of review by a county 
          board of education (CBE) when an appeal of interdistrict 
          pupil attendance occurs; (2) specifies that if, after two 
          months, no decision by the two governing boards or CBE has 
          been made regarding an appeal, the district of residence 
          shall receive the funding attributable to the pupil; and 
          (3) provides that a parent or guardian is physically 
          employed within the boundaries of that district if employed 
          during a majority of the time that the pupil is scheduled 
          to be in school.

           BACKGROUND  

          Current law provides for several means to authorize 
          interdistrict attendance of a pupil who resides in one 
          school district but wishes to attend public school in 
          another school district:

          The main authorization provides for interdistrict 
          attendance when both the district of residence and district 
          of proposed attendance agree. This process allows the 
          parent or guardian of a pupil requesting interdistrict 
          attendance to appeal to the county board of education in 
          the event that either district refuses the requested 
          transfer. In addition, current law allows the governing 
          board of a school district for a period not to exceed two 
          school months to provisionally admit to their schools a 
          pupil who resides in another district, pending a decision 
          of the two boards, or by the CBE upon appeal, regarding the 
          interdistrict attendance. The provisional attendance may be 
          counted by the district of attendance for revenue limit and 




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          state apportionment purposes. (EC � 46600 et. seq.)

          A second form of interdistrict attendance authorizes a 
          pupil to attend school in a district where the pupil's 
          parent works, rather than where the pupil and parent 
          reside. The district where the parent is employed is not 
          required to admit the pupil but is prohibited from refusing 
          admission on the basis of the arbitrary consideration such 
          as race, ethnicity, sex, parental income, scholastic 
          achievement. The receiving (parental employment) district 
          may also refuse the transfer if it determines that the 
          costs of the transfer would exceed the added revenues (thus 
          preventing mandated costs.) Either district of residence or 
          parental employment may prohibit the transfer if it would 
          negatively affect a desegregation plan and the district of 
          residence is not required to allow more transfers than 
          specified limits based upon the size of the district. (EC � 
          48204)

          A third authorization is under District of Choice (DOC) 
          provisions.  Under the DOC program, a school board may 
          declare the district to be a DOC willing to accept a 
          specified number of interdistrict transfers.  The DOC 
          program provides protections against districts targeting 
          students in specific residential neighborhoods, on the 
          basis of a child's actual or perceived academic or athletic 
          performance or any other personal characteristic.  A DOC 
          may reject the transfer of a pupil if the transfer of that 
          pupil would require the district to create a new program to 
          serve that pupil, except that a DOC shall not reject the 
          transfer of a special needs pupil, including an individual 
          with exceptional needs, and an English learner.  DOCs are 
          required to collect specific data about the students who 
          transfer to their district and report that data to 
          surrounding districts and to the state.  This data is 
          required to be reported annually to the Legislature and the 
          Governor, and the Legislative Analyst's Office (LAO) is 
          required to prepare a comprehensive evaluation of the 
          program.  (EC � 48300 et. seq.)

           ANALYSIS
           
           This bill:

           1)   Clarifies that the hearing required by a county board 
               of education (CBE), within 30 calendar days after an 




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               appeal is filed must be an impartial hearing.

          2)   Specifies the review by the CBE shall be limited to 
               the following questions:

               a)        Whether the district acted in accordance 
               with an interdistrict 
                         attendance agreement, where applicable.

               b)        Whether the district followed the district's 
               policy on interdistrict 
                         attendance.

               c)        Whether the district provided the parent or 
               guardian with an 
                    opportunity to provide information relevant to 
                    the interdistrict attendance request.
               d)        Whether there is relevant and material 
               evidence that was not 
                         considered by the district. 

          3)   Requires if after two months, no decision has been 
               made regarding either an interdistrict attendance 
               agreement or an appeal, by the two governing boards or 
               the CBE, the school district of residence shall 
               receive the revenue limit and state apportionment 
               funding attributable to that pupil.

          4)   Provides that, until July 1, 2013, a school district 
               may deem a pupil to have complied with residency 
               requirements for school attendance in a district if at 
               least one parent of the pupil is physically employed 
               within the boundaries of that district during a 
               majority of the time that the pupil is scheduled to be 
               in school.

          5)   Requires reimbursement to local agencies and school 
               districts to be made if the Commission on State 
               Mandates determines that this act contains costs 
               mandated by the state.

           STAFF COMMENTS  

           1)   Need for the bill.  The author's office contends that 
               the Education Code contains no consistent standard of 
               review for county boards of education (CBEs) to follow 




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               with regard to handling appeals for interdistrict 
               attendance permits. Without required standards for 
               impartial review, decisions can be perceived as 
               arbitrary by the parties before the county board. In 
               addition, this measure would also set parameters that 
               directly link the parent's employment to the school 
               week.

           2)   Consistency of appeal review seems reasonable  . It 
               seems reasonable to have a clear and consistent review 
               approach by CBEs with regard to interdistrict transfer 
               appeals as envisioned in this bill.   Many school 
               district policies provide for an initial district 
               appeal if an interdistrict attendance request is 
               denied; in addition, all school districts are required 
               to inform parents of their right to appeal to their 
               local CBE.  

               According to the author their intent is to insure a 
               fair and consistent review, and not impede parent and 
               pupil rights and while keeping open the possibility 
               that unique circumstances may arise. With this in 
               mind, staff recommends an amendment that rather than 
               having a CBE review "whether there was relevant and 
               material evidence not considered," a more direct and 
               consistent review question would be on page 4, line 
               11, "(iv) Whether there is relevant information, which 
               in the exercise of reasonable diligence, could not 
               have been produced or which was improperly excluded at 
               the hearing before the district governing board."

           3)   Changes to Provisional Attendance Funding Seem 
               Premature.   The bill attempts to motivate school 
               districts and CBEs to act in a timely manner regarding 
               interdistrict agreements or appeals by creating a time 
               certain cutoff whereby the district of residence 
               receives funding attributing to that pupil.  However, 
               given the changes envisioned by this bill by providing 
               for a clear, consistent, and streamlined approach to 
               appeal reviews, as well as the lack of information on 
               how many pupils the current process applies to, a 
               change in current statute may be considered premature. 
               Therefore, staff recommends that Section 2 of the 
               measure be deleted. 

           4)   Continuing to provide parents and guardians with the 




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               flexibility to enroll their children in schools near 
               their workplace  provides parents with the opportunity 
               to engage in their children's education.  The author's 
               intent is to provide for reasonable parameters for 
               parent employment as it relates to school attendance. 
               For example, at present, a parent could obtain 
               part-time weekend employment within the boundaries of 
               another school district and use that employment to 
               justify school attendance for their child.  However, 
               the author recognizes that Senator Pavley also has a 
               measure (SB 381) dealing with the identical provision 
               of law and is willing to defer to her measure to 
               establish a fair and reasonable nexus between a 
               parent's physical place of employment and the where 
               their child attends school.  Therefore, staff 
               recommends, with the concurrence of the author, 
               Section 3 of the measure be deleted.
           
            5)   Background on impact of outgoing interdistrict 
               attendance on Los Angeles Unified School District .  
               According to information provided by the author, LAUSD 
               has issued approximately 10,350 interdistrict 
               attendance permits to pupils in 2010 with an 
               associated loss of approximately $52.5 million in 
               average daily attendance.   

               In 2010, 314 appeals were filed with the Los Angeles 
               County Office of Education; of these appeals -- 107 
               appeals granted, 76 were denied, and the remainder of 
               appeals (131) were either withdrawn by the parent, 
               abandoned, or postponed.

           6)   Technical amendments  . The following technical 
               amendments are recommended:
               On page 3, line 22, strike out "an impartial" and 
               insert: a
               On page 4, line 22, after "Government" insert: Code
               On page 4, line 30, after "education" insert a comma
               On page 4, line 32, after "Code" insert a comma
               On page 5, line 10, after the second "county" insert a 
               comma
               On page 5, line 16, strike out "Students" and insert: 
               Pupils

           7)   Similar legislation  . SB 381 (Pavley) -- this bill 
               extends authorization for a pupil to enroll in school 




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               where the parent or guardian of that pupil is 
               employed, rather than resides. The inoperative date 
               would be extended from July 1, 2012 to July 1, 2017.

           SUPPORT  

          Los Angeles Unified School District (sponsor)

           OPPOSITION

           Los Angeles County Office of Education