charter school fiscal management spring 2012 presented by: fiscal crisis and management assistance...

Charter School Fiscal Management

Spring 2012

Presented by:Fiscal Crisis and Management Assistance Team (FCMAT)California School Information Services (CSIS)Schools Legal ServicesMichael Ammermon, CPA, CFE

General Information

• Charter school fiscal management binder• Copies of the presentation• Additional reference materials

• Explanation of today’s format

• Feel free to ask questions

• Please turn cell phones OFF

Did you Know?• Forty-one states, plus the District of Columbia, allow for charter schools.

• California was 2nd in the nation to authorize charter schools.• More than 4,900 charter schools serving 1.6 million children operate across

the US in January 2010.• These 4,900 schools are overseen by 872 authorizers, one-third of

which are in California.• Nationwide, California has the largest number of charter schools serving the

largest number of students.• Charter schools educate approximately six percent of all California

students.• There are more than 982 charter schools in California, with more than

412,000 students enrolled.• Charter schools are located throughout 50 of California’s 58 counties.

Did you Know?, cont.

• Many charter schools, though successful in raising student achievement, are closing their doors due to their lack of knowledge about managing the business and fiscal requirements of their schools.

• CDE data shows nearly two-thirds (65%) of all charter schools that closed since 2004 reported positive trends in API growth and failed for reasons unrelated to successful academic performance.

• Both the authorizers with oversight responsibility and the charter schools they serve need to better understand and meet their respective responsibilities.

What Can We Do?• Make sure there is an understanding that:

• Effective financial management of charter school resources is as important to the success of a charter school as the strength of the curriculum or the dedication of its founders.

• Collaborative efforts between public schools and charter schools are in the best interest of all of our students; it is essential to understand each other’s regulatory and reporting environments.

• The need for effective site-based financial management at charters has never been greater.

• Sharing best practices to build capacity for effective financial management is a win-win situation.

What Can We Do?, cont.

• Strong, proactive oversight is critical to everyone’s success

• So is open communication

What Is A Charter School?

Presented by:

Bill Hornback, Counsel, Schools Legal Service

Michelle Plumbtree, Chief Management Analyst, FCMAT

What Is A Charter School?• Publicly funded elementary or secondary schools that:

• may operate independently of an existing school district structure;

• may provide instruction in any grade or grades, K through 12. • Usually created or organized by a group of teachers, parents,

community leaders, a community-based organization, or the school district.

• Exempted from significant portions of the California Education Code in exchange for performance-based accountability.

• Overseen by charter school authorizers, who must ensure that the school is abiding by their charter and meeting its accountability goals.

What Is A Charter School?, cont.

• Charter schools may be authorized by a district, a county board of education (CBE), or by the California State Board of Education (SBE).

• Specific goals and operating procedures for the charter school are detailed in the "charter."

• Additional details are often set forth in a memorandum of understanding or “MOU.”

• Improve student learning; • Increase learning opportunities for all students, especially

those who are academically low-achieving; • Encourage the use of different and innovative teaching

methods; • Create new professional opportunities for teachers; • Provide parents and students with expanded choice within the

public school system;• Provide competition within the public school system to spur

improvement in all schools;• Hold schools accountable for meeting

measurable performance outcomes.

What is the Purpose of Charter Schools?

• Charter schools are an integral part of the California educational system;

• The establishment of charter schools should be encouraged;• Charter schools are part of the public school system, but are

free from most of the state laws that uniquely apply to school districts;

• Charter schools are under the jurisdiction of the public school system and the exclusive control of the officers of the public schools, and are entitled to full and fair funding;

• The laws governing charter schools are to be liberally construed to effectuate their intent.

What is the Legislative Intent?

What Laws Apply to a Charter School?

• Constitutions, both state and federal• The California Charter Schools Act• All federal laws (e.g., special education)• Laws generally applicable to governmental entities but not

specifically aimed at school districts (e.g., open meeting laws)

• Provisions of law related to teacher retirement and employee relations.

• Others listed in the materials.

What is the Difference Between a Dependent and an Independent Charter School?

• Traditionally, a “dependent” school is treated as another school of the authorizer, for all purposes.

• Traditionally, an “independent” school may only be a school of the authorizer for limited purposes, such as special education.

• There is a growing trend among school districts to mix things up.

What is a “Conversion” Charter School?

When an existing school site is converted into a charter school, whether an independent or dependent charter school, the school is likely to be considered a “conversion” charter school.

Other Important Considerations

• LEA status• Classroom- or nonclassroom-based instruction• Countywide charters – no appeal of a denial, but there is appeal of a nonrenewal or revocation• Statewide charters • Highly qualified teachers• Core academic subjects

Surrender of Charter

• The voluntary termination of charter school activities• No process is necessary other than CDE being

notified• Authorizer should review potential liability for claims

due to:• final audit• disposition of assets• transfer of pupil records

Charter School Finance in California

Presented by: Michelle Plumbtree, Chief Management Analyst, FCMAT

Funding Mechanism - Direct or Local Funding

Direct funded = from the state to the charter schoolLocally funded = from the state to the chartering authority to the charter school

• Decision is made each May via the CDE “funding survey”

Either way, funding is supposed to be equitable relative to that received by traditional school districts

Charter School Funding Model

• Three main income sources:• General Purpose Block Grant per ADA

• State averages per grade level• Rate does not consider variances in the cost of

living or revenue limit from district to district• Categorical Block Grant per ADA

• Covers 26 state-funded programs• Includes additional funds for EIA pupils

• Funding for specific programs for which charter schools may apply

General Purpose Block Grant

• Largest source of unrestricted charter school revenue• Funded on enrollment or average daily attendance (ADA)

• No protection for declining enrollment in California• Based on statewide average revenue limits per ADA by

grade level• Funded by a combination of:

• State aid• Local property taxes (“in lieu of property tax”)

General Purpose Block Grant, cont.

Most recent estimates for 2011-12*:K-3 $5,0764-6 $5,1537-8 $5,3089-12 $6,141

*Will be updated again after second principal apportionment is certified at the end of June 2012

Categorical Block Grant

• Unrestricted funds • Consolidated amount based on individual restricted

categorical programs• i.e. funding in lieu of a long list of categoricals

• Not eligible to apply separately for these programs• See CDE website for list

• http://www.cde.ca.gov/sp/cs/as/cscatblkgrinfo.asp

Categorical Block Grant, cont.

• Unrestricted funds • Consolidated amount based on individual restricted

categorical programs• i.e. funding in lieu of a long list of categoricals

• Current estimate 2011-12, $385 per ADA• Not eligible to apply separately for these programs

• See CDE website for list• http://www.cde.ca.gov/sp/cs/as/cscatblkgrinfo.asp

Categorical Block Grant, cont.

To the extent they are eligible:• Locally-funded charter schools typically apply through

their chartering agencies.• Direct-funded charter schools apply directly to the

appropriate state or federal agency.

Funding for Selected Programs

• Special education• Federal• State (SELPA)

• Others by application, if the charter school complies with all statutory requirements of the program:• K-3 CSR• Quality Education Improvement Act (QEIA)

• Automatically• Lottery

Funding for Selected Programs, cont.

Federal categorically-funded programs - No Child Left Behind:Title I, Neglected or DelinquentTitle I, Part A, Basic GrantTitle II, Part A, Teacher & Principal Training & RecruitingTitle III, LEP StudentsTitle IV, Part A, Safe & Drug-Free Schools & CommunitiesTitle VI, Part B, Rural Education AchievementTobacco-Use Prevention Education

Nonclassroom-Based Instruction

Nonclassroom-based instruction occurs when a student is notscheduled for at least 80% of the instructional time in aclassroom. Funding penalties are invoked if criteria are not being met. It includes, but is not limited to:

• Independent study• Home study• Work study• Distance and computer-based education

Questions:• How do we structure our instructional methodologies?• Do we align with any state requirements to maximize funding?

Other Potential Revenue

Charter schools can negotiate with their chartering agency for some sources of district funding, even though the district is not required to share, including:

• Share of basic aid excess taxes• Forest reserve funds• Federal impact aid• Parcel tax

Revenue Enhancement

Funding based on student attendance• Consider student attendance incentives• Increased attendance rates = increased funding

• Offer awards to students for:• Best attendance rate• Most improved attendance rate

• Use donated funds to fund prizes/rewards • Avoid gift of public funds issue

Revenue Enhancement, cont.

School calendars • Evaluate daily student attendance patterns

• Identify times when attendance is low• Adjust school calendar accordingly• Eliminate days that drag down ADA

Grants• Apply….but:

• Be wary of match requirements!• Can create financial burden if not properly

understood• Key questions

• What programs can we fund with this grant?• Can we fund this program once the grant expires?• Will this grant fund my cost increases over time

and my indirect costs?

Donations• Philanthropy/fundraising is an excellent source of

supplementary funding for charter schools• Make sure it’s a donation, not a fee• Identify how the donation will be used when collected

• Donors should always know how their donations are used

• Do not use one-time donations to fund ongoing programs• Allocate as though they are one-time funds

Indirect costs• That portion of costs associated with the overhead of

operating a charter school• Every resource contributes to the need for indirect costs

• Thus, every resource should be charged• Each resource has specific limitations on indirect cost

charges

New and Expanding Charter Schools

Special advance apportionments for new charter schools• Start the flow of funds – new schools

• General purpose funds• Categorically funded programs – federal and state

• Start the flow of funds – expanding schools• Significant growth• Grade level expansion

• Offset opening costs

Declining Enrollment

School districts funded at greater of current or prior year ADA • Not available to charter schools• State won’t fund the same ADA for both the district and the

charter school• The “sending entity” must deduct the ADA from the prior

year ADA count for purposes of calculating fundable ADA

• Can’t fund same ADA twice in the same year

Expenditure Control Strategies for Charter Schools

Internal Controls

A strong internal control structure is critical to controlling expenditures.•This includes:

• Policies and procedures used by staff• Accounting and information systems• The work environment• The tone set by management• The professionalism of employees

• Covered in more detail in other parts of today’s presentation

Budget Controls

Position control• System of internal control that ensures all positions funded

by the charter school are properly authorized • Check and balance between:

• Staff who authorize position changes (Business Department)

• Staff who manage vacancies (hire/adjust/terminate) (HR Department)

Budget Controls, cont.

Economic uncertainty reserve• Guidance should be provided in charter document or MOU

with authorizing agency• Consider building reserves in difficult fiscal times

• Establish a base and add for:• enrollment fluctuation• staffing/program fluctuation• equipment/facility failure

Budget Reductions

Plan for the worst, hope for the best• Review priorities and commitments

• Update multiyear financial projection• Make adjustments now; don’t wait

• Savings have a multiplier effect• Match expenditures to projected funding levels

• Eliminate structural deficit in budget• Implement new plan ASAP

Budget Reductions, cont.

Develop a list of reductions that exceeds your reduction target …… and then prioritize

• Board authorization to implement list by priority• Avoids necessity of constant, never-ending budget cutting

sessions• Revisit priority at budget reporting intervals and as information

changes• Budget adoption, interim reports, year-end closing, audit

report

Budget Monitoring

Enrollment and staffing• Update projections monthly as actual counts are taken

• Budget adjustments should be implemented immediately if actual data indicates a material difference from the projected amounts

• Mid-year staffing adjustments may also be necessary to prevent fiscal distress as a result of overstaffing• But not recommended, if it can be avoided• Disrupts instructional program

Budget Monitoring, cont.

Budget overages (actual exceeds budget)

• Preventing overages• Use position control system• Use “hard stops” on purchase orders

• Responding to overages• Present budget modifications monthly• Resolve overage condition

• Identify condition that led to overage• Correct the condition

General Ledger Monitoring

Monitoring general ledger accounts is also critical to soundfiscal monitoring

• Cash reconcile items that are not cleared• Accounts receivable/payable differences between

accruals and actual receipts/payments• Inventory that is over/understated• Payroll clearing accounts that are not reconciled

• Payroll clearing is the most commonly underscrutinized area

Compensation

Largest portion of budget• Components of increased cost

• Compensation increases (nonsalary schedule)• Salary schedule increases/bonuses• Step and column salary schedule movement• Benefit rate increases (statutory)• Benefit program changes (contracted)

Compensation, cont.

Identify available dollars• Available new revenue

• COLA, growth• Less increased fixed costs (previous commitments)

• Step and column salary schedule movement• Statutory benefit rate increases, utilities, insurance• Increased staffing needs

• Less discretionary allocations• New/expanded/restored programs• Other priorities

• Equals amount available for compensation

Compensation, cont.

Desperate fiscal climate• Traditional budget reduction approaches may not be

sufficient• Creative solutions may be needed to stay fiscally and

cash solvent• May need to consider:

• Compensation deferrals• Can’t pay now, but may be able to later

• Compensation rollbacks• Across-the-board reductions

• Salaries/benefits/both

Compensation - Statutory Benefits

Statutory benefit rates likely to increase• Retirement systems have suffered substantial losses in recent

years• Rate adjustments have been implemented • Benefit reductions are under consideration

• Social Security, Medicare in need of significant fixes• Proposals are politically risky

• Nothing concrete proposed to date• Unemployment insurance costs on the rise

• More layoffs = higher rates

Compensation - Contracted Benefits

Health and welfare benefit programs• Medical, dental, vision, life, etc.• Health care reform may not provide timely solutions

• May increase costs • Increase purchasing power

• Join a JPA• Consider HMOs, health savings accounts (HSAs)• Review benefit caps on premiums, copays, deductibles• Validate dependent enrollments

Position Costs

Staff positions to meet charter school’s program needs• But no more• Overstaffing - and unfunded compensation agreements -

are the largest components of financial failures!• Consider options before creating permanent positions

• Use substitutes/extra duty/overtime• Contract out (if legal)

• Short-term cost < permanent cost

Contributions to Restricted Programs

Some restricted programs require contributions from unrestricted funding sources•Some are mandated by law•Some are discretionaryManage contributions

• Limit contributions to the amounts necessary• If unexpected contribution occurs, investigate

• Educate the organization that the contribution occurred and why

• Determine the level of commitment• One-time vs. ongoing

Budget Development Best Practices for Charter Schools

Budget Development – Governance

Adopt charter school board policies and regulationsregarding budget management• Guidance to staff regarding expectations for the budget• Establish:

• Goals and objectives for the charter school• Instructional/financial/other

• Process by which budgets are aligned with goals and objectives

• Process to identify budget assumptions• Process to develop budget

Budget Development – Strategies

Develop budgets with a multiyear perspective• Be thinking in a three- to five-year time frame

• Primary focus on budget year• Additional focus on subsequent years

• Not as detailed• Organization needs a compass to see where it’s going

• Action plan• What we need to do, and when• To achieve goals and objectives

Budget Development – Strategies, cont.

Use conservative assumptions• Estimate low on revenues, high on expenditures• But don’t overdo it!

• Estimating too high or too low can create serious problems• Loss of credibility• Harm to programs• Negative effect on student performance

Allocate new revenues (if any!) to needs, then wants• Fund the base and related fixed-cost increases first

• Inflationary effect on supplies, etc.• Benefit increases

• Statutory and contractual• Step and column movement across salary

schedules (if any)• Contractual/debt service obligations

Then, if funds are available, allocate new funds to wants

• Program development, expansion, restoration• Compensation increases• Building reserve levelsThis process also works when funding decreases.

Multiyear Financial Projections

State law identifies the duties of a charter authorizingentity• Charter authorizing entity must monitor the fiscal

condition of charter schools • But charter schools are NOT subject to AB 1200

county oversightA budget and a multiyear financial projection (MYFP)are integral information for the oversight function• Two to five years after budget year

Multiyear Financial Projections, cont.

MYFP focus• Meet required reserve for economic uncertainty

• Not required by AB 1200, but could be required as part of MOU

• Deficit spending trends? Must:• Increase revenue• Decrease expenditures• Or both

Report Format

Budget report format - Narrative• How the budget aligns with the goals of the board• How it supports student learning • Significant assumptions used to develop the budget• Budget reduction detail

• Response to reduced funding, declining enrollment or other factors

Report Format, cont.

Unaudited actuals report• Format may be prescribed by the state • Basis for independent financial audit• Last chance to affect the charter school’s financial

status before the audit begins

Report Format, cont.

Typical list of supplemental information • Budget assumptions for revenues and expenditures• Analysis of enrollment and average daily attendance (ADA)

trends • An organizational chart• Statement of cash flow for the current and subsequent

fiscal year• Profit and loss statement• Disclosure of all multiyear fiscal obligations, such as loans,

lines of credit, etc., for the next three years

Cash Flow Management Techniques for Charter Schools

The Importance of Cash Flow

• Cash flow is an important factor in determining the fiscal health of the charter school.

• Many schools are using their reserves to balance their budget.• Using reserves affects future cash flow.• Less reserves means less cash.

• It is possible to maintain economic reserves in the budget, yet be out of cash.

• Cash shows no mercy – you either have it or you don’t

State Cash Flow Management

As the state continues to experience shortfalls in revenue,they must have a means to improve their cash flow.

• Deferrals have been the key to improving the state’s cash situation, but have become detrimental for LEAs.

• Cash flow will continue to be challenging to manage for LEAs as deferrals are added, increased or lengthened.

Deferrals2003-04 State started deferring the June payment into July2007-08 February apportionment deferred into July2009-10 State started partially deferring portions of the

April and May apportionment into August2010-11 State added multiple deferrals

**July to September**September to December**March to April**Part of April and May to July**Deferred funds to July and August delayed to September

Deferrals, cont.

2011-12 Changes made to existing deferrals and new deferrals**July, August and October 2011 delayed

to January 2012**Partial deferral of March apportionment

to August 2012**Additional partial deferral of April

apportionment to August 2012

The Cash Concept

It is often difficult to conceptualize the specific nature of cash • Assets – liabilities = fund balance

But is the fund balance cash?• No

• Assets are not all cash • Liabilities are accrued debts

• Therefore the fund balance is not all cash

Managing Receivables and Payables

Clean up receivables and payables as soon as possibleduring the fiscal year

• Best practice indicates that the majority of receivables and payables should be finalized by October 31• Any outstanding balances should be investigated:

• Is this still a valid receivable or payable?• When will it be received or paid?

Reconciling Cash• Best practice is to reconcile cash each month for each

fund• Not reconciling cash can result in significant

surprises once the backlog is caught up• The charter school will be able to more accurately

anticipate cash borrowing needs• What needs to be reconciled?

• The county treasurer’s records• The charter school’s financial system records• The bank’s records

• Remember to balance clearing accounts

Cash Flow Projection Tools

• Spreadsheets• Financial management software• FCMAT’s Budget Explorer software

• Web-based, free of charge• BECS - Budget Explorer for Charter Schools

• Currently in planning & development phase• Easy to use, improves planning/decision-making• Upload data from DAT file, excel or manual input

Apportionment Schedules

For the revenue or receipts section of the cash flowprojection, apportionment schedules are available

• These account for much of charter schools’ incoming cash.

• Education Code Section (E.C.) 14041 in California details the amount of apportionments for charter schools.

Month Original Schedule 2011-12 Schedule Projected 2012-13 Schedule

July 5.0% 0.0% 0.0%

August 5.0% 0.0% 0.0%

September 9.0% 11.7% 11.7%

October 9.0% 0.0% 0.0%

November 9.0% 9.0% 9.0%

December 9.0% 9.0% 9.0%

January 9.0% 25.3% 25.3%

February 9.0% 0.5% 1.6%

March 9.0% 0.0% 1.2%

April 9.0% 4.6% 5.2%

May 9.0% 1.5% 2.3%

June 9.0% 0.0% 0.0%

July 22.6% 20.8%

August 15.8% 13.9%

Total Principal Apportionment

100.0% 100.0% 100.0%

Apportionment Schedule E.C. 14041(a)(2), (3), and (4)

In-Lieu Property Taxes

August 6%September 12%

October 8%November 8%December 8%January 8%February 8%

March 1/3April 1/6May 1/6June 1/6

Categorical Apportionments• Federal apportionments are considered Tier I

• No flexibility • No transfers, except as allowed for No Child Left Behind (NCLB)

programs.• Funds will be apportioned according to established schedules.

• California Tier III categorical programs have experienced a change in cash flow.• The 41 programs transferred from restricted to unrestricted will

now follow the regular apportionment schedule (i.e., 5, 5, 9 . . . ) for cash flow purposes

• See the CDE’s worksheet

Local Revenues

Other local revenues• The charter school is the best estimator of other

local revenues• Use historical percentages and information on

which to base the school’s current projection• Update the projections frequently to reflect

actuals to date

Expenditures• Estimating the timing of expenditures is critical for cash flow purposes

• Dividing the budgeted amount by 12 months is not a good strategyIt most likely will not give you an accurate picture of the LEA’s cash needs to meet obligations

• As the fiscal year progresses, analyze projected spending amounts• Use the projected budget as a basis for the cash flow

• Make sure all reductions or increases are accounted for in the cash projection

• For example, if spending freezes have been enacted, have the anticipated savings been accounted for in the cash flow projection?

Cash Flow Projections

• Critical to staying successful and solvent• Should be updated monthly • Review cash flow projections at board meetings• Project 18 to 24 months in the future• Prepare for all funds• Need to be closely monitored for accuracy• Ensure different scenarios taken into consideration

• “trigger” cuts• deferrals

Projecting Cash Flow

Now, ask these questions, based on the cash projection:• Is cash negative at any time?• What is the negative amount?• If so, what borrowing options are most appropriate?

• Remember, the cost of borrowing reduces available resources for students

• Can I pay it back?

Projecting Cash Flow, cont.

If borrowing is necessary at year end, the most frequently used option is a temporary transfer from another fund (i.e. internal borrowing)• Are there sufficient balances in other funds?• How long will the borrowing be needed?

A midyear RANs may be an option as well• See following section on cash borrowing options

Cash Borrowing Options

External borrowing – three options:• Sell revenue notes

• Revenue anticipation notes (RANs)• Piggyback on district TRANS

• Private financial institutions• Lines of credit• Private loan

• Sell accounts receivable

Now, with state deferrals, even more agencies require borrowing

Cash Borrowing Options, cont.

Outside experts are needed for legal and financial mattersrelated to the issuance

• A financial advisor can save you time and money• Legal counsel can ensure that the transaction complies

with all laws and regulationsSome agencies issue RANs by pooling their needs withother agencies

• Saves on costs of issuance• Coordinated through various public agencies/nonprofit organizations

Borrowing from a financial institution is an option• Line of credit or private loans

• Secured or unsecured• Issuance costs and interest rates tend to be higher than

for a RAN• Private financing tends to be more difficult to acquire

• May find qualification requirements onerous• Particularly for new or start-up charter schools

Accounts receivable “factoring” (sales) is another option• Less common• Involves selling accounts receivable to a financial institution

at a discount• Need significant receivables for this option to generate

meaningful cash flow• Relatively expensive• RAN is likely less expensive

Other Cash Flow Options

The state of California provides cash flow loans to charterschools• Used for start-up costs• Relatively short-term (3-5 years)• Reasonable interest rates and issuance costs• Check with CDE; visit the website Deferral exemptions• Check with CDE; visit their website• http://www.cde.ca.gov/fg/fi/ir/mardef112.asp

Other Cash Flow Options, cont.

Current legislation, AB 1576:• Amends the state’s Education Code to allow a county

board of education or county superintendent to issue, on behalf of charter schools, treasury revenue anticipation notes, or TRANs.

• Allows for a county office of education or county superintendent to make a loan to a charter school not located within its county, and it protects the county and the state from any liability should the loan default.

Cash Borrowing Options

Loans require the charter school to repay the lender• What happens if the charter school can’t?

• It’s GAME OVER• Charter schools are not eligible for an emergency

state loan in California.• Fund balance can be low or negative, but cash cannot

Relationships

Developing a relationship with your lender and other partiesinvolved is critical to successful borrowing

• Financial institution• County office of education• County treasurer• Management company (if applicable)• Sponsoring LEA• Financial advisor/legal counsel

2012-13 Governor’s Proposal for Charter Schools

Presented by:

Proposed Increase in Funding, 2012-13

Increase of $50.3 million for the General Purpose Block Grantand the Categorical Block Grant

*Amount will vary based on statewide average revenue limits

General Purpose

Block Grant*

Categorical Block Grant

Total Funding

K-3 $5,117 $410 $5,527

4-6 $5,193 $410 $5,603

7-8 $5,346 $410 $5,756

9-12 $6,188 $410 $6,598

Proposed Increase in Funding, 2012-13, cont.

Estimated 2012-13 funding rates include:• 3.17% COLA• 21.666% deficit• ADA growthFinal amounts could vary up or down by $20 per ADA. CDE recalculates the general purpose rates at each apportionment.

Other Proposals from the Governor for 2012-13

Ways to make things more consistent between traditional andcharter schools, Governor proposes:“Enhancing Charter School Funding”:

• Authorizing agency could include their charter schools in TRANS issuances

• Authorizing agency would no longer review charter school deferral exemptions

Other Proposals from the Governor for 2012-13, cont.

Also proposed: “Investing in Charter School Facilities”:

• Nonclassroom-based charter schools could participate in the charter school facility program

• Streamlines application process and eligibility determinations“Improving Charter School Working Capital”:

• Authorizes the California School Finance Authority to refinance working capital revenue bonds

• Expands working capital financings to include charter management organizations (CMOs)

Audits, Fraud, and Internal Controls

Presented by:Michael W. Ammermon, CPA, CFE

• Do you need internal controls if everyone is completely honest?

• Can fraud occur if you have great internal controls?

• Could your auditor miss ongoing fraud?

Audits, Fraud, and Internal Controls

CASE STUDY

ALBOR CHARTER SCHOOL

Audits, Fraud, and Internal Controls, cont.

(((VIDEO)))

There are many words for fraud

What is your word for fraud?

Fraud, cont.

Misappropriation

Fraud, cont.

MisappropriationTheftEmbezzlement

Fraud, cont.

Let’s focus on the two terms of –

Misappropriation and fraud

Fraud, cont.

What is MISAPPROPRATION OF FUNDS?

Fraud, cont.

Definition of Misappropriation

“In law, misappropriation is the intentional, illegal use of the property or funds of another person for one's own use or other unauthorized purpose, particularly by a public official, a trustee of a trust, an executor or administrator of a dead person's estate or by any person with a responsibility to care for and protect another's assets (a fiduciary duty).”

Definition of Fraud

Black’s Law Dictionary defines fraud as:“all multifarious means which human ingenuitycan devise, and which are resorted to by oneindividual to get an advantage over another byfalse suggestions or suppression of the truth. Itincludes all surprise, trick, cunning or dissembling, and any unfair way by which anotheris cheated.”

WHY ARE CHARTER SCHOOLS A TARGET FOR FRAUD ?

Fraud, cont.

What Should We Be Looking For?

Fraud, cont.

What are Some Examples of Fraud?

List A Few…

Fraud, cont.

• Falsified or exaggerated attendance• Not recording vacation or sick time off• Paying vendor “buddies” for no work product• Purchasing supply items for personal use• Unsubstantiated travel expenses• Duplicate or fictitious employees

Fraud, cont.

What ingredients are needed for fraud?

How many ingredients?

Fraud, cont.

THREE INGREDIENTS NEEDED FOR FRAUD

Fraud, cont.

MOTIVE

Fraud, cont.

OPPORTUNITY

Fraud, cont.

ACCESS

Fraud, cont.

WHAT IS SO IMPORTANT ABOUT motive, opportunity, and access?

Fraud, cont.

Think about these three things when planning an audit or administering oversight

• WHO HAS OPPORTUNITY?• WHO HAS MOTIVE?• WHO HAS ACCESS?

Access or No Access?

OPPORTUNITY and ACCESS IS LIMITED with a good system of what?

Fraud, cont.

We have all heard the words “internal controls” over and over. Simple internal controls do a lot in helping to prevent fraud and errors that look like fraud.

Internal Controls

Simple INTERNAL CONTROLS Help mitigate fraud, improve protections against motive, opportunity, and access, as well as shield employees from accusations of fraud.

Internal Controls, cont.

What Do Internal Controls Include?

An organizational culture that promotes awareness and takes fraud seriously at all levels

What are some audit and oversight metrics that should be considered when evaluating a charter school’s financial performance?

What Should We Consider?

How do you evaluate your charter school’s performance and ability to continue as a going concern?

How do we Evaluate Performance?

Evaluate the audit report?

Compare the charter’s budget, first interim, second interim, and unaudited actuals?

How do we Evaluate Performance?, cont.

Better Charter Oversight and Auditing Metrics

Commonly Evaluated More Details

• Evaluate audit report• Compare budget, 1st, 2nd,

and unaudited actuals

• Prepare a comparison of audit reports and trend analysis

• Compare budget and unaudited actuals within the year and against the prior year

Better Charter Oversight and Auditing Metrics, cont.

• Trend analysis at the object code level.• Common size analysis with revenue and expenses.• Examine AGED accounts payable at the individual

vendor level.• Audit ADA WITHIN the charter’s attendance program.• Evaluate the charter each year as a boing concern.

Better Charter Oversight and Auditing Metrics, cont.

Attendance Mismatches

Going Concern Checklist

Effective Oversight, including Monitoring Processes and

Procedures

Presented by:

What is Effective Oversight

• Charter schools shall be held accountable for meeting measurable pupil outcomes (E.C. section 47601(f))

• Annual independent audits shall be conducted and “deficiencies shall be resolved to the satisfaction of the chartering authority” (E.C. section 47605(b)(5)(l))

The Legislature's Intent:

What is Effective Oversight, cont.• Charter can be revoked for:

• “Failure to meet generally accepted accounting principles, or engaging in fiscal mismanagement” (E.C. section 47607©(3))

• “Failure to meet or pursue any of the pupil outcomes identified in the charter” (E.C. section 47607©(2))

• “Committing a material violation of any of the conditions, standards, or procedures set forth in the charter” (E.C. section 47607©(1)) or“violating any provision of the law” (E.C. section 47607©(4))

What is Effective Oversight, cont.

• California Research Bureau study revealed that between 5 and 20% of all authorizers fail to perform each of the above duties

• Consistent with state auditor’s 2002 report

What’s really happening:

• Academic performance criteria. (API growth target)• Alternative assessment in charter• Classroom visits

• Teaching methodology• Standardized test scores (STAR test)• Parent feedback

Educational Program Oversight

• Hiring practices and policies• Personnel policies• Employee handbook• Credentials/highly qualified personnel• Personnel files• Complaint procedures• Discipline, dismissal and release• Charter provisions• Payroll/wages• STRS/PERS/benefits

Personnel/Labor Oversight

• Governing Board: Brown Act, Political Reform Act, Conflict of Interest laws

• Public Records Act• Dispute resolution and complaint procedures• Nonprofit corporation: Bylaws and articles of

incorporation• Nondiscrimination policies and ethnic balance• Third party and employee complaints• Instructional minutes

Governance/Legal Oversight

• Attendance accounting• Independent study compliance• Tuition free• Nonsectarian• Insurance coverage and indemnification• Contractual disclaimers• Health and safety policies• Disaster preparedness

Governance/Legal Oversight, cont.

• Student admissions and enrollment• Student discipline• Service delivery - special education

Student Discipline and Special Education Oversight

• Identify at least one staff member as a contact person.• Visit each charter school at least annually.• Ensure that the charter school’s files comply with all

reporting requirements• Includes providing the annual audit report to the

chartering entity, state controller and county superintendent

• Notify the CDE if a renewal is granted or denied, the charter is revoked, or the school closes.

• Monitor the charter’s fiscal condition.

The law requires:

• A preliminary budget by July 1• First interim report by December 15

• For changes through October 31• Second interim report by March 15

• For changes through January 31• A final unaudited report by September 15

• For previous fiscal year• Also called “Annual Report of Revenue

and Expenses”• Annual Audit Report

Each charter school annually required to provide:

• Charter schools shall promptly respond to all reasonable inquiries from the chartering authority, the county office of education, the State Superintendent, and shall consult with these agencies regarding any inquiries (E.C. 47604.3)• Access not dependent on Public Records Act

• Chartering authority may “inspect or observe any part of the charter school at any time” (E.C. 47607(a)(1))• No requirement to schedule the visits

Other Requirements:

• Although charter schools are not subject to AB 1200 requirements, FCMAT recommends that chartering authorizers establish similar guidelines and standards found in AB 1200 compliance/oversight to their charter schools• Can be done via the charter or the MOU

• Charter authorizers can use any financial information it obtains from the charter school to assess the fiscal condition of the charter

• Charter authorizers differ significantly on the oversight activities that they perform

• There is little documented evidence that authorizers are performing all of the state-mandated oversight functions

• Most charter authorizers charge charter schools the maximum allowable amount for oversight activities, however few authorizers document the time or cost associated with the activities

Review:• Multiyear financial plan• Short or long-term debt• Potential liability claims• Bank account balances/cash flow• Audit information• Reserves• Staffing and enrollment projections• Internal controls

What are the best practices for financial oversight?

• Work as a team• Build trust; foster open communications• Always be aware of what is going on• Be proactive - don’t wait for issues to occur• Be transparent• Verify compliance with the charter, MOU and

the law

What are the best practices for oversight (in general)?

• When there are issues, document your efforts to resolve them.

• Review over time if policies, practices, and preferences are working.• Suggest revisions if they are not working.

• What would a jury think I should have done?

What are the best practices for oversight (in general)?

Oversight Reimbursement• Supervisorial oversight fees, maximum charge:

• 1% of charter school revenue*• 3% if facilities provided substantially rent free

• There appears to be no consistency in authorizer activities or reported expenses

• Most authorizers report that they spend more than the cap amount they are able to receive, but they don’t account for the funds they receive

*Charged on general purpose revenue and the categorical block grant

Oversight Reimbursement, cont.

• Of the 16 states that base authorizer reimbursement on a percentage of charter school funds, most allow authorizers to charge two and three percent of a school’s general fund budget in authorizing fees.• Compared to California’s 1% or 3%

Liability Issues

• “An authority that grants a charter to a charter school to be operated by, or as, a nonprofit public benefit corporation is not liable for the debts or obligations of the charter school, or for claims arising from the performance of such acts, errors, or omissions by the charter school...”

BUT ONLY IF• “...the authority has complied with all oversight responsibilities

required by law, including, but not limited to those required by Sections 47604.32 and subdivision(m) of Section 47605 (relating to annual audits)”

Memorandum of Understanding (MOU)• It’s important to develop a comprehensive MOU as a

framework for the relationship and to supplement the charter provisions. • The purpose is to clarify financial and operational

issues. • An MOU is an agreement between the authorizing

agency and the charter school.• Allows the chartering agency to identify expectations. • Not required by charter law but highly recommended.• Is a binding legal agreement once approved.

Memorandum of Understanding (MOU), cont.

• The MOU should define specific expectations and responsibilities of the two parties, such as:• student performance• expectations for educational programs• special education• frequency of school site visits• financial reporting requirements• services provided by the sponsoring agency• insurance coverage requirements

Elements of a comprehensive MOU outline expectations regarding oversight roles and responsibilities and a well defined periodic review process through:• An expanded business plan• A facilities plan regarding the use and payment for

space that also reflects the terms and conditions for use of district property.

• An administrative and support services plan

• It is critical to clearly spell out the relationship between charter schools and their chartering agencies.

• The MOU is traditionally enforced as part of the charter, and replaces any inconsistent language in the charter.

• The State Board of Education and Department of Education have a form of MOU available.

County Office Authority

• To monitor or conduct an investigation into the operations of the charter school based on written complaints by parents or other information that justifies such actions.

• To review or audit the expenditures and internal controls of a charter school at any time during the fiscal year if there is reason to believe that fraud, misappropriation of funds, or other illegal fiscal practices have occurred.

• May request the county office or Fiscal Crisis and Management Assistance Team (FCMAT) to review the fiscal or administrative condition of a charter school.

Annual AuditsMust contract for an audit by April 1 of each year • Contract with an auditor from the Certified Public

Accountants Directory published by the State Controller’s Office

Must submit an annual independent financial audit by December 15 of each year to the following:• State Controller’s Office• CDE’s Charter Schools Division• CDE Audit Resolution Office• Authorizing agency• County office of education where the school is located

Annual Audits, cont.

The audit shall be conducted in accordance with General Accounting Office (GAO) standards for financial and compliance audits and in accordance with the audit guide adopted by the Education Audit Appeals Panel (EAAP).

Delays: There is no provision in the law for an extension on a charter school audit.

Annual Audits, cont.

Audit findings• To ensure a favorable recommendation for renewal,

each audit must be free of material findings and exceptions, or corrective action plans must have been implemented in a timely manner.

• The auditor is required to review the correction, or plan of correction, to determine if the exceptions have been resolved in the subsequent year audit

Presented by: Gary Quiring, CSIS Implementation Specialist

Fiscal Crisis & Management Assistance Team

Charter School Reporting Requirements

Reporting Requirements Topics

• Charter School Reporting Requirements• Ed Code• Data categories• How the certified data is used• Consequences for not certifying• Charter school closure requirements• Charter school reauthorization conversion requirements• Charter school inactive status requirements

Reporting Requirements Topics, cont.

• Authorizing Agency Requirements• Ed Code• Charter school closure requirements• Charter school reauthorization conversion

requirements• Best Practices to Avoid Issues

• Petition process• Relationship with charter• Monitoring• Closure policy

Charter School Reporting Requirements

Ed Code Requirements• Part 28. Chapter 6.1 Public Schools Accountability Act of

1999, Article 2. Public School Performance Accountability Program, 52051.5 – Inclusion of Charter Schools:For purposes of this chapter, all references to schools shall include charter schools.

• Part 33, Chapter 10. California Longitudinal Pupil Achievement Data System, 60900 – Development and implementation of system; goals; characteristics:(k) For purposes of this chapter, a local educational agency shall include a county office of education, a school district, or charter school.

Charter School Reporting Requirements, cont.• Data Categories

CALPADS Data Reporting Categories

Fall 1 Annual Student Enrollments/Exits Student Information Student Programs

Fall 2 Certificated Staff Demographics Certificated Staff Assignments Courses Provided Student Course Enrollment

Spring 1 Student Enrollments/Exits Student Information Student Programs

End of Year 1 Student Course Completion and Grades (7-12) CTE Participants, Concentrators, and Completers

End of Year 2 Student Program Participation

End of Year 3 Student Discipline

End of Year 4 Student Waivers (CASHEE)

How Certified CALPADS Data are Used• Provide the Department of Finance with enrollment counts used

for budget projections. • Student enrollment counts are the charter’s official enrollment

counts for the year and are used for multiple enrollment-based funding formulas, including the Public Charter School Grant Program (PCSGP)

• Data are published on DataQuest to provide the general public with access to aggregate information on the state’s schools

• Data are used to respond to ad hoc report requests from policy makers, researchers, and other entities

How Certified CALPADS Data are Used, cont.• State Reports

• California Basic Educational Data System (CBEDS)• Language Census• Governmental Code Sections 13073 and 13073.5 • California Code of Regulations, Title V, Section 97

• Federal Reports• State NCLB Consolidated State Performance Report (CSPR)• Student National Origin Report• Carl Perkins• Titles VI and IX of the Civil Rights Act of 1964

How Certified CALPADS Data are Used, cont.

• Title III eligible immigrant counts • Funding LEAs for the NCLB Title III Immigrant Program• Reporting to the United States Department of Education

(ED) on the Consolidated State Performance Report• The higher of the two counts taken in the Fall 2 and

Spring 1 will be used for funding and reporting purposes

How Certified CALPADS Data are Used, cont.

• English language acquisition status (ELAS) counts• Counts of eligible limited-English-proficient students for the

purposes of funding LEAs for the NCLB Title III LEP Program

• LEP counts for the USDOE on the Title III Biennial Report and other federal reports

• Language Census report of English language acquisition statuses, services, and strategies

• Direct certification of students who are eligible for free meals

How Certified CALPADS Datawill be used in 2011-12

• Career technical education concentrators and completers• Preidentification of state assessments and for the reporting

of assessment results in subgroups

Consequences for Not Certifying

• Zero enrollment reported if Fall 1 is not certified• Charter marked as failing AYP if Fall 1 is not certified

(charters serving grades 7-12 only)• Charter may be invoiced if Fall 1 enrollment counts are

below the PSCGP estimates• NCLB Title III Immigrant Program funding will be 0 if Fall 2

and Spring 1 are not certified• Authorizing agency has grounds for nonrenewal or revocation

of charter

Common Charter Reporting Problems

• Meeting CALPADS reporting requirements is a low priority for charter staff or management.

• New charter staff are unaware of state reporting requirements or do not understand the amount of work required.

• Charter participation in CALPADS trainings is minimal.• CALPADS reporting is only addressed during the certification

timeframe, not year round.• Charter user accounts in CALPADS are

not maintained or misused.

Data Reporting Roadmap Topics

• State reporting changes for 2011-2012

• CALPADS roadmap for 2011-2012 & 2012-2013

• Lessons learned

• Best practices

• Charter school closure requirements

• Data management services provided by FCMAT/CSIS

• Resources

Presented by: Bill Hornback, Counsel, Schools Legal ServiceMichelle Plumbtree, Chief Management Analyst, FCMAT

Common Issues

Governance Issues: What Laws Apply

• There is an unresolved dispute in the state over the application of Government Code Section 1090

• Govt. Code Section 1099 – Incompatible Offices• Govt. Code Section 1226 – Incompatible Activities• Govt. Code Section 53227 – Employees on the Board• You get to decide the answer, each time you look at a

charter petition, an original petition, or on appeal, or on renewal

What Laws Apply, cont.

• Some laws are accepted to apply, such as:• Political Reform Act – Government Code• Brown Act – Government Code

• Another grey area is the granting agency’s right to a seat on the board of directors of any not-for-profit corporation operating a charter school.

• The answer is: Whatever you want it to be..

Pupil Fees, Deposits and Other Charges

ACLU Lawsuit

• September 2010 lawsuit being pursued by the American Civil Liberties Union (ACLU) of Southern California and two students and their families, representing students statewide.

• A settlement was reached in 2010 and legislation was passed through both the state Assembly and Senate to put such a system in place, but Governor Jerry Brown vetoed AB 165 in October, saying “this bill takes the wrong approach.”

Free School System

• California Constitution provides for a free school system• Applies to charter schools, too

• Since 1874, the California Supreme Court has interpreted this to mean students are entitled to be educated at the public’s expense.

• Title 5, California Code of Regulations, Section 350, specifically states:“A pupil enrolled in a school shall not be required to pay any fee, deposit, or other charge not specifically authorized by law.”

Free School System, cont.• E.C. 47605(d) specifically prohibits a charter school from

charging tuition.• But does not mention fees or other charges

• Only some additional Education Code sections specifically authorizing fees have been explicitly made applicable to charter schools.• Fees for field trips• Fees for food

• Can’t charge other “fees authorized by law” unlessthe fees do not relate to an activity that is anintegral component of public education.

More Tuition Rules

• Charter schools shall not charge tuition (E.C. section 47605(d)(1)). • Can’t require a parent to contribute volunteer service

as a form of tuition• Charter schools can’t receive public funds for a pupil if

that same pupil is also attending a private school that charges the student’s family for tuition (E.C. section 47602(b)).

• Charter schools cannot “fine” parents when students are tardy or truant

Nonallowable Fees

• Public schools, including charter schools, cannot levy fees as a condition for participation in any class, whether elective or compulsory. This includes:• Security deposits for locks, lockers, books, class

apparatus, musical instruments, uniforms or other equipment.

• Fees for participation in either curricular or extra-curricular activities.

• All supplies, both necessary and supplemental, must be provided free of charge whenever a particular curricular or extra-curricular program is adopted.

Nonallowable Fees, cont.

• Gym or physical education clothes• EC Section 49066 states, “No grade of a pupil

participating in a physical education class may be adversely affected due to the fact that the pupil does not wear standardized physical education apparel where the failure to wear such apparel arises from circumstances beyond the control of the pupil,” such as lack of sufficient funds.

Nonallowable Fees, cont.

• The CDE has stated the position that schools may require students to purchase their own gym clothes of a district specified design and color so long as the design and color are of a type sold for general wear outside of school. Once the required gym uniforms become specialized in terms of logos, school name or other similar characteristics not found on clothing for general use outside of school, they are considered school supplies and the district must provide the uniforms free of charge.

Additional Information on Fees

• Donations are always allowable• But they really must be voluntary!• Child’s ability to participate in a school activity can not

be tied to making a donation• The availability of a fee waiver does not make an

otherwise unlawful fee permissible.• CDE has released a new fiscal management advisory,

#11-01, titled “Pupil Fees, Deposits, and Other Charges”. • We’ve included it in your reference binder

Gift of Public Funds

• California Constitution, Article 16, section 6 addresses the subject of gift of public funds:

• Prohibits making any gift of public money to any individual (including public employees), corporation, or other government agency.

• “ ... the Legislature shall have no ... power to make any gift, or authorize the making of any gift, of any public money or thing of value to any individual … whatever …”

Gift of Public Funds, cont.• Expenditures of school funds must be for a direct and

primary public purpose to avoid being a gift. • Expenditures that most directly and tangibly benefit

students’ education are more likely justified.• Must be within the scope of a school entity’s jurisdiction

and purpose.• To justify the expenditure of public funds, the governing

board must determine that the expenditure will benefit the education of students within its schools.

• Expenditures driven by personal motive are not justified even if they have a long-standing custom or are based on benevolent feelings.

Gift of Public Funds, cont.

• If the governing board has determined that a particular type of expenditure serves a public purpose, courts will almost always defer to that finding.• Put in board policy

• The following can be considered a gift of public funds unless in board policy:• Flowers• Candy• Donations to charity

Gift of Public Funds, cont.

• Expenses CANNOT be considered a gift of public funds• Must have a direct or substantial purpose.• Misappropriation of public funds is considered a

criminal act, with no monetary limit specified.• Better to be safe than sorry.

Are gifts allowable?

• Not allowable, even if small in amount• Many think that “de minimus” gifts, those of

trivial or little value, would be okay (under $20/person).• Most courts would disagree.

Are Awards Allowed?

• Authorized by E.C. 44015• To employees for exceptional contributions; to students

for excellence.• The board is required to adopt rules and regulations

about awards.• If there is no policy or regulations, no awards are

allowed• Can’t exceed $200 unless in board policy.• Awards to community members are not considered

authorized.• Birthdays, weddings, funerals and holidays are not

considered an award.

Are Awards Allowed?, cont.

• Awards to employees are allowed if employees:• Propose procedures or ideas that are adopted and

result in eliminating or reducing district expenditures or improving operations

• Perform special acts or special services in the public interest

• Make exceptional contributions to the efficiency, economy or other improvement in operations of the district

Is Employee Clothing/Attire Allowed?

• No specific statute or case authorizing such expense• Could definitely be considered a gift of public funds

• Not allowable unless required to perform his or her duties as a coach, club advisor, etc. or if considered an “award” under E.C. 44015

Are Employee Appreciation Meals Allowed?

• Appreciation meals do not qualify as awards• Attorney General says they are not “actual and

necessary” per E.C. 44032• They don’t provide a direct and/or substantial

purpose, so would be a gift of public funds

Good Business Practices

• Establish board policy and administrative regulations regarding what is considered allowable/unallowable

• Establish procedures to follow if questions arise• Set parameters for determining appropriateness• Assign a specific employee in the business office to

provide assistance• Provide annual training

Before we Break for Lunch:Please choose your Break-Out

SessionsCharter School Reporting Requirements,

including CALPADS and Data ManagementAudits, Fraud and Internal ControlsVarious Legal Topics, including Petitions,

Renewals, and Facilities, as well as time to ask Miscellaneous Questions

Foretelling The Future

Presented by:

Foretelling The Future

• Charter schools will continue to increase.• School districts are converting schools to charters to

get start-up grant money.• The virtual real-time classroom is already here.• A movement is under way to relieve virtual classroom

programs from independent study rules/restrictions.• Statewide/countywide charters dead, or dying?

This Is What’s Happening Already

Foretelling The Future, cont.

• Keep communication open• Conflicts and issues hurt everyone, including

students• Always be prepared — be proactive• Stay involved• Ensure the provided oversight and assistance is

adequate

What do we need to do?

Where to Go for Help

Fiscal Crisis and Management Assistance Team(FCMAT)

Website: www.fcmat.org

• Management assistance• On-site technical assistance• AB139 extraordinary audit• Fiscal crisis• Fiscal advisor/fiscal expert• Online help desk• Professional development

Charter School Division Contact Information

Charter Schools Division California Department of Education,

1430 N Street, Suite 5401, Sacramento, CA 95814Phone: 916-322-6029 Fax: 916-322-1465email: charters@cde.ca.govWebsite: www.cde.ca.gov/sp/cs

Questions and Answers

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