As we've worked to reframe and restructure adult education over the last few years, we've consistently noted the importance that the new, revised structure and distribution of resources under what is now deemed the "Adult Education Block Grant" (AEBG) be simple, clear, efficient and protected.
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Of greatest importance to help ease the transition this year to the AB 86 / AEBG regional consortia approach, the FY 15-16 budget provided dedicated funding directly to K-12 school districts in the amount of the districts' maintenance of effort for adult education to sustain current capacity. This component was critically important and one of the key items we advocated heavily for to preserve current capacity now and in the future. Further, AEBG allows for each region to decide whether its adult school members receive their funding directly from the CDE or from a fiscal agent. We believe this flexibility must be maintained and would argue the distribution of funds, particularly for the K-12 adult schools, be disseminated through their existing respective state fiscal infrastructures (CDE and the CCCO) to avoid disruption, confusion, delays, and denigration of either part of the dual delivery system.
Under the AEBG, the Block Grant Funding is provided to the CCCCO as the state-level fiscal agent with the option of entering into an interagency agreement with the CDE to distribute funds. As outlined for the distribution of MOE funds to K12 Districts in 2015-2016, the CCCCO would provide the K-12 allocation to CDE who will in turn distribute the K-12 dollars to K-12 districts/adult schools based on their regional consortia plans. The CCCCO will distribute allocations to local community college districts, based on regional consortia plans.
Sending the resources for the entire adult education system through a single funding stream has been and is likely to continue to be problematic for K-12 adult schools for a host of reasons, including:
- Distribution of resources through a fiscal agent at the local level will run the risk of distancing adult education programs from K-12 districts. Regional plans build upon the unique identity of K-12 adult schools and so it is imperative that they continued to be tied to CDE and their individual school districts. This connection is critically important in terms of access for the students the K-12 system serves; the learning mechanisms associated with basic skills needs that builds upon the K-12 model of teaching to ensure proper uptake of the education that is more closely aligned to K-12 curriculum; staffing issues related to contracts, oversight, development, etc.; accreditation; federal oversight and matching; and more. Should the direct fiscal connection be lost to CDE and the individual school districts, K-12 adult schools could be in serious danger of losing their identity and the undeniable benefit to the students we serve could be destroyed as school districts move away from support of adult schools, thereby disconnecting the access so many of our students rely upon.
- Distribution of resources through a regional fiscal agent in either system, - K-12 adult school or CCC - as predicted, has proven problematic as the governing boards in either system must approve the allocation and associated programmatic components of the consortium partners plan to disseminate the resources. This is inappropriate and violates the separation of powers between the two systems. Further, there are multiple examples of failure of a regional CCC fiscal agent to disseminate the planning grant funds to its school district partners. This is illustrative of the contracting and governing complexities that can be incredibly detrimental, particularly for K-12 adult schools going forward.
- It has taken considerable time to establish fiscal infrastructure to allocate resources resulting in K-12 adult schools not receiving a timely allocation of funding. Many K-12 districts may be unwilling to float the allocation each school year until such time that the fiscal infrastructure is working.
- Additionally, any delay in receiving a K-12 adult schools funding could result in the school districts feeling the need and/or pressure to issue March 15th layoff notices and close infrastructure.
- Distancing K-12 adult schools fiscally from their district could also present challenges for necessary infrastructure, as some districts may choose to disallow use of district infrastructure or increase costs by charging fees/rent to utilize facilities.
- CDE is currently charged with administering the WIA/WIOA and other federal funding associated with adult education. Much of these resources are dependent upon maintenance of effort by the state such that the federal dollars supplement an existing program rather than fund it alone. Leveraging of such federal funding requires reporting on the state interest and outcomes, particularly in the K-12 adult schools. Separating the K-12 adult school funding from CDE as it relates to federal funds could present a challenge for CDE's reporting requirements.
To be clear, the statute under Education code Section 84909(e) continues the Governor's principle of subsidiarity, providing flexibility for regions to decide whether allocation of funds via a fiscal agent or direct funding to members makes the most sense for that particular region. Further, the statute does not preclude consortia from altering course in any given year on this point allowing regions to opt to have a fiscal agent one year and direct funding the next. While we do not condone or wish to promote changes each year on this point, it is important for consortia members to understand that they can change the structure if they feel it is important to their members or district.
Also of note, for those regions that opt to have a fiscal agent, the fiscal agent should be merely serving as the bank and does not have the authority to approve or deny allocations to members following consortium approval of the allocation process and distribution. It should be clear that these funds should be passed through and neither governing boards nor school district boards have the authority to insert themselves in the allocation decisions. Further, distribution of funds should be made on an allocation basis, not on a reimbursement basis.
With regard to reporting requirements associated with the receipt of AEBG funds, it should be made clear that each member that receives funding from the AEBG bears responsibility for reporting its allocation, use of funds, outcomes, and etc. whether or not a fiscal agent is established for a consortium. More specifically, whether or not a consortium chooses a fiscal agent or direct funding members must individually track their own expenditures in their own accounting systems and report either to the consortium or state. In this regard, the only difference relative to reporting requirements for those consortia that have a fiscal agent is that the fiscal agent certifies the reporting information. For those consortia that opt to have direct funding, that member serves as their own fiscal agent and follows their own district policies and procedures. In this case, the only reporting difference is that members must certify the information they report themselves and report it directly to CDE or the CCCCO. The reporting requirements for all intents and purposes are the same.
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| Approaching the Capitol, Leg Day 2014 Photo Credit: Hitomi |
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