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California State Auditor Report Number : 2016-112

School Library Services
Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services

Responses to the Audit


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California Department of Education

October 27, 2016

Elaine M. Howle, State Auditor
California State Auditor
555 Capitol Mall, Suite 300
Sacramento, CA 95814

Subject: “School Library Services: Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services,” Report No. 2016-112, November 2016

The California Department of Education (Education) appreciates the opportunity to comment and provide proposed corrective actions to the recommendations outlined in the California State Auditor’s (CSA) Audit Report No. 2016-112, titled: “School Library Services: Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services.”

Overall Comments

To provide better perspective to the CSA’s audit, Education has the following overall comments related to the auditors’ fieldwork and reporting.

2
1

Comment 1: Information and Data Requests – Although Education questioned the auditors need for student-level information, including school enrollment, demographic, program participation, and course enrollment information, the auditors insisted on obtaining this information without a defined objective or purpose. To meet the CSA’s short timeframes and demands, Education reprioritized assignments to complete their requests. In addition, it was necessary for Education to have numerous phone calls and e-mails with the CSA to help them gain an understanding of how to review the data provided. Based on the audit report text, it appears that this extensive information request was neither necessary or within the audit scope and objectives.

3

Comment 2: Negative-Biased Text – Throughout the report, the auditors made statements with negative connotations regarding Education’s data collection processes without providing the appropriate context. For example, the auditors did not report the fact that changes to the data collection process were made to directly improve the data quality for librarians and other staffing information, after concerns were raised by School Library Advocates. Instead, the auditors reported only narrow limitations of and within the data collection process.

Recommendation No. 1:

To better understand the conditions of school libraries statewide and to raise stakeholders’ awareness of the State Education Board’s adopted model standards, Education should do the following:

Education’s Comments and Corrective Actions

Concur. Education will review the relevant CALPADS data submitted and certified by LEAs and identify those with a significant decline in staffing than the prior year. Based on a review of comparison data, Education will determine if it would be necessary to contact the school districts to follow up and verify the accuracy of the data. In addition, on October 18, 2016, in the semi-annual Webinar to CALPADS LEA users, participants were reminded of the importance of accurately reporting School Librarian data ( https://csis.fcmat.org/Pages/October-18-2016-CALPADS-Information-Meeting.aspx - slide 73).

If you have any questions regarding Education’s comments or corrective actions, please contact Kevin W. Chan, Director, Audits and Investigations Division, by e-mail at kchan@cde.ca.gov.

Sincerely,

Michelle Zumot
Chief Deputy Superintendent of Public Instruction






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE CALIFORNIA DEPARTMENT OF EDUCATION

To provide clarity and perspective, we are commenting on the California Department of Education’s (Education) response to our audit. The numbers below correspond to the numbers we have placed in the margin of Education’s response.

1

As we state in the Scope and Methodology, audit objective 4 was to determine whether the number of credentialed teacher librarians is insufficient based on available indicators and to determine what factors contribute to the shortage. For example, we present student‑to‑teacher librarian ratios and student enrollment information by location in Table 4. In fact, we engaged in several conversations with Education representatives explaining the need for the requested data and pointed out this specific audit objective to them.

2

Audit standards require that we obtain sufficient and appropriate evidence to support our audit findings, conclusions, and recommendations. As such, we required Education’s assistance during the course of the audit.

3

Education states that we did not report its reasons for making changes to its data collection process; however, we included the explanation of Education’s deputy superintendent of the District, School, and Innovation Branch (branch deputy) in the Audit Results. The branch deputy stated that Education changed its way of collecting data at the request of teacher librarians who wanted to be categorized as teachers who teach specific courses, rather than as staff providing pupil services. Given the large decrease in the number of teacher librarians that school districts reported in fiscal year 2015–16, Education’s changes did not improve the data quality for librarians.

4

Education is incorrect in its assertion. As described in the Audit Results, we indicate that Education has provided staffing information to the Commission on Teacher Credentialing (Teacher Credentialing) since fiscal year 2010–11. Further, we consulted with Education to determine that April was a reasonable time frame for Education to provide Teacher Credentialing the staffing information each year.

5

We disagree with Education’s assertion that it is not feasible or realistic to provide staffing information to Teacher Credentialing by April of each year, as we determined this time frame based on Education’s input and estimation that it could complete this task between March and May. To the extent that Education now believes that April is no longer feasible, we look forward to its identification of an annual time frame it can meet in its 60-day response to our audit.



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Commission on Teacher Credentialing

October 27, 2016

Elaine M. Howle
State Auditor
Bureau of State Audits
555 Capitol Mall, Suite 300
Sacramento, California 95814

Dear Ms. Howle:

Commission staff have reviewed the findings of the state auditor report titled, School Library Services: Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services. We greatly appreciate the department’s support and thoughtful dialogue in working with the Commission in putting the final draft report together.

Introduction

The Commission’s core mission is to ensure integrity, relevance, and high quality in the preparation, certification, and discipline of the educators who serve all of California’s diverse students. The Commission recognizes and promotes excellence in the preparation and practice of California’s education workforce. The agency also values equity, quality, inclusiveness and diversity in standards, programs, practices, people and the workplace and is dedicated and committed to the education and welfare of California’s diverse students.

We appreciate that the findings in this report help to support and respect the mission of the Commission and work to help ensure that qualified teachers are in place throughout our school districts and libraries.

Response to Audit Findings

Below you will find the Commission’s comments and clarifications to the findings provided in the final draft report.

Level of Service

1

The following statements can be found on pages 4 and 24 of the draft report:

“Although the State’s Commission on Teacher Credentialing (Teacher Credentialing) has issued guidance that this practice is one way to comply with state law, schools that obtain services in this way are unlikely to provide as many library services to their students and teachers as schools that employ their own teacher librarian.” (Page 4)

“Although the California Commission on Teacher Credentialing (Teacher Credentialing) issued guidance that this practice is one way to comply with state law, schools that obtain services in this manner are unlikely to provide as many library services to their students and teachers as schools that employ their own teacher librarians.” (Page 24)

Commission’s Response: The Commission has issued this non-binding guidance in an effort to be helpful, but the responsibility to monitor the level of service is not within the Commission’s authority. The Commission provides information on all legal assignment options for employers and a library contract is one of the legal options.

Misassignments

The following statements can be found on pages 5 and 28 of the draft report:

“However, Teacher Credentialing  [redacted content]  stated that they did not identify this activity as an inappropriately staffed position, referred to as a misassignment, because they lack the authority to monitor the assignments of classified staff.” (Page 5)

2

“However, state law gives Teacher Credentialing broad authority to ensure competence in the teaching profession and establish sanctions for the misuse of credentials and misassignment of credential holders. We therefore believe that Teacher Credentialing should continue to obtain this staffing information from Education and begin using it to identify and follow up on potential misassignments using its existing authority.” (Page 28)

Commission’s Response: Because there was a contract in place and the Commission does not monitor the level of service, the contract satisfies the requirement. The Commission does not have authority to monitor non-certificated individuals.

Material Selection

The following statement can be found on Table 3 on page 22 of the draft report:

The asterisk states that “…schools use principals or library staff to select materials, a service the Commission on Teacher Credentialing only authorizes teacher librarians to provide.”

Commission Response: The regulations specify that teacher librarians select materials for school or district libraries. The ‘select materials’ in the footnote to the table could be misunderstood to be any materials and the regulation is specific to materials for the school or district library. This footnote would be more accurate if it stated: …schools use principals or library staff to select materials for the district or school library, a service that the Commission on Teacher Credentialing only authorizes teacher librarians to provide.

Response to Recommendation

Below is the Commission’s response to the report recommendation as it relates to the agency.

To strengthen its monitoring of staff assignments, Teacher Credentialing should work with Education to identify potential misassignments by comparing annually the staffing information reported by school districts to Education against Teacher Credentialing’s credential records. Further, Teacher Credentialing should incorporate the identified misassignments into its existing notification, reporting, and sanctioning structure.

Commission Response: Staff agrees that using the CDE data could help sharpen the process of identifying misassignments and could allow assignments to be monitored annually rather than once every four years.

Again, we thank and appreciate the Auditor’s willingness to work with us in formulating the final draft of this report. We look forward to the release of the final report and working towards implementing the recommendations put forth in order to continue supporting teachers and students in California. Please contact us with any other questions or comments.

Sincerely,

Mary Vixie Sandy, Ed.D.
Executive Director






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE COMMISSION ON TEACHER CREDENTIALING

To provide clarity and perspective, we are commenting on the Commission on Teacher Credentialing’s (Teacher Credentialing) response to our audit. The numbers below correspond to the numbers we have placed in the margin of Teacher Credentialing’s response.

1

While preparing our draft report for publication, some page numbers shifted. Therefore, the page numbers Teacher Credentialing cites in its response do not correspond to the page numbers in our final report.

2

Teacher Credentialing incorrectly cites the statement from the Audit Results, which relates to certificated staff, in discussing the monitoring of classified staff. As we state in the Audit Results, we believe that Teacher Credentialing has the authority to use California Department of Education’s data on employed teachers to identify the misassignment of certificated individuals.



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Redlands Unified School District

October 27, 2016

Andrew Lee
Team Leader
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

RE: Report Number 2016-112 - School Library Services

Dear Mr. Lee:

The following is the Redlands Unified School District's ("District") response to the State Auditor's findings and recommendations received by us on October 21, 2016.

Redlands Unified School District is committed to ensure students are college, career, and life ready. Our mission is clear in that our students will be empowered with the knowledge and commitment necessary to confront the challenges of our changing world as they become the leaders of the 21st century. It is the District's desire to produce technology-competent individuals who can transform information into knowledge, think critically, and nurture lifelong learning. This is achieved by the District's practice of continual school improvement on a regular basis.

Please find below our responses to the State Audit Report 2016-112.

Recommendation No.1

Ensure that teacher librarians are involved in the selection of library materials at each school.

Response to Recommendation No. 1

The District agrees with this recommendation as it relates to the operations of the Redlands Unified School District elementary schools, and will take actions to address this recommendation, including:

Recommendation No. 2

Consider ways to leverage the teacher librarians they already employ to offer a broader range of services to all grade levels.

Response to Recommendation No. 2

The District agrees with this recommendation and has already taken steps to address this recommendation, including:

Recommendation No. 3

Use the model standards to assess the needs of their school library programs and address any identified needs during their LCAP process.

Response to Recommendation No. 3

1

The District disagrees with this recommendation to the extent the audit concludes the Redlands Unified School District analyzed the common state standards to the model library standards in isolation. As such, the report indicates that the district provided an 'analysis showing that several of the model standards goals align with those of the State's common core standards.' In/act, the in-depth analysis completed by the District demonstrated how the District's program, outlined in the District's Scope & Sequence for K-12 (which includes adopted curriculum aligned to common core standard), incorporated a great percentage of the model standards. A sampling analysis was completed.for grades 3, 8, and 12. The model standards are covered in 77% of the 3rd grade Scope and Sequence; 85% of the 811' grade Scope and Sequence; and 85% of the 12th grade Scope and Sequence. The purpose of the analysis was to demonstrate how the District examines its local needs for the LCAP by analyzing data of student achievement stemmed from a robust and comprehensive K-12 Scope and Sequence, which includes much of the model library standards.

Further, the District understands the purpose of the LCAP is to "reflect a simple, yet complete story of needs, goals, services, and investments that will have positive outcomes for students. It is intended to be flexible, allowing/or resource allocation choices that align to local needs. It is the vehicle to pursue what is needed based on locally determined priorities and needs. " The LCAP process determines the needs that are to be addressed within the LCAP budget and document. The information found across sections of the District's LCAP provides an accessible story about the needs, approach, and investments the District is making to support success for all students. As a result, there are numerous specific components in the District's LCAP that address the model standards.

Recommendation No. 4

Require their schools to participate in Education's annual school library survey.

Response to Recommendation No. 4

The District agrees with this recommendation as it relates to the operations of the Redlands Unified School District. The District will participate in the school library survey, and asks that the information pertaining to this survey be emailed to Miki Inbody, Assistant Superintendent, Educational Services Division at miki_inbody@redlands.k12.ca.us In this way, the survey will be dispersed as a mandatory requirement, and all school site administrators will be advised accordingly.

Sincerely,

Lori Rhodes
Superintendent of Schools






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE REDLANDS UNIFIED SCHOOL DISTRICT

To provide clarity and perspective, we are commenting on the Redlands Unified School District’s (Redlands Unified) response to our audit. The number below corresponds to the number we have placed in the margin of Redlands Unified’s response.

1

We stand by our recommendation that Redlands Unified should use the Model School Library Standards for California Public Schools, Kindergarten Through Grade Twelve (model standards) to assess the needs of their school library programs and address any identified needs during the local control accountability plan process. Redlands Unified states that its analysis shows the model standards are covered in 85 percent of the grade 12 Scope and Sequence; however, its analysis is limited to the 13 overarching standards that continue across all grade levels. As we state in the Audit Results, the model standards consist of smaller, more specific objectives that students should achieve by the end of a specified grade level or grade span, such as the span of grades nine through twelve in high school. As we note in the Audit Results, the common core standards’ goals overlap with fewer than half of the model standards’ 64 goals for students in grades nine through 12. In addition, the model standards provide other specific guidance related to library services that is not included in the common core standards, such as goals related to library staffing and resources, which Redlands Unified did not address in its analysis.



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Sacramento County Office of Education

October 27, 2016

Via Electronic Mail to AndrewL@auditor.ca.gov

Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Re: School Library Services Audit

Dear Ms. Howle:

The Sacramento County Office of Education (SCOE) has received your draft school library services audit report. We appreciate your staff’s work on this audit and your invitation to respond to the audit recommendation involving SCOE. Our response is below.

Recommendation

1

“To strengthen library programs in their counties and help school districts comply with the law, the county offices of education in Sacramento County, …should provide guidance to their school districts on using teacher librarians for the provision of library services, completing Education’s annual survey, and identifying the needs of their school library programs by using the model standards as part of their LCAP process.” (Pages 9, 41-42)

SCOE Response

The draft audit report finds that “the law does not clearly define required library services or establish a means for ensuring their provision” and “state law does not specify the minimum level of library services school districts must provide.” (Page 19) Therefore, we understand that the recommendation above is not intended to suggest that county offices of education are out of compliance with existing law, but rather to suggest practices that you believe would strengthen library programs and assist school districts if implemented.

2

The final unredacted audit report is not yet available. Nevertheless, our initial reflection is that to increase library services, school districts will not need additional guidance. They will need additional resources. This lack of resources is referenced in your draft report and highlighted by your comparison of California’s education expenditures with those in other states, however, the recommendation seems to suggest that more library services will occur when there is more guidance. Similarly, the title of the report – “School Library Services: Vague Laws and Lack of Monitoring Allow School Districts to Provide a Minimum Level of Library Services” – suggests that more specific state laws and increased monitoring could increase the level of library services. California’s underfunded education system is a zero sum situation – without additional resources, more library services will result only from a corresponding loss in other important programs, such as arts, civics, etc.

SCOE is committed to helping Sacramento’s nearly one-quarter million K-12 students receive quality education services. Therefore, once we have had an opportunity to review the final unredacted audit report and the practices upon which it is based, we will consider and determine whether additional guidance to our school districts will assist in strengthening school library programs in the county.

Thank you for your time and consideration. If you have questions or need additional information, please let us know.

Sincerely,

David W. Gordon
Sacramento County Superintendent of Schools






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE SACRAMENTO COUNTY OFFICE OF EDUCATION

To provide clarity and perspective, we are commenting on the Sacramento County Office of Education’s (Sacramento County Education) response to our audit. The numbers below correspond to the numbers we have placed in the margin of Sacramento County Education’s response.

1

While preparing our draft report for publication, some page numbers shifted. Therefore, the page numbers Sacramento County Education cites in its response do not correspond to the page numbers in our final report.

2

Sacramento County Education states that school districts will not need additional guidance to increase library services. As we state in the Audit Results, school districts may be unaware that the Model School Library Standards for California Public Schools, Kindergarten Through Grade Twelve (model standards) are one of the State’s recommended academic content and performance standards. As a result, some districts may fail to identify the needs of their school library programs and allocate resources accordingly. In addition, as we note in the Audit Results, a school district we visited in Sacramento County had principals or classified staff perform certain activities that require a certificated teacher librarian. Thus, we believe that school districts could benefit from receiving additional guidance on using teacher librarians for the provision of library services. Finally, as we note in the Audit Results, less than half of the schools in Sacramento County responded to the California Department of Education’s annual library survey. As a result, school districts could benefit from additional guidance to improve their participation in this mandatory survey.



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San Bernardino County Superintendent of Schools

October 27, 2016

Ms. Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Dear Ms. Howle:

Thank you for your interest in library services for California’s public schools. This letter is a formal response to the draft audit report (“Report”) “School Library Services: Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services” presented to the San Bernardino County Superintendent of Schools (SBCSS) on October 21, 2016.

1

As the draft Report indicates, the State Board of Education adopted Model School Library Standards for K-12 students in 2010. Additionally, state law requires school districts to provide library services, but does not clearly define library services and does not require school districts to directly employ teacher librarians to provide such services. The Report also clearly acknowledges that there is no legal requirement for county offices of education to support districts in the provision of library services (pg. 24).

2

With that being said, on page 19 of the Report, the words “do little” suggest that there is some oversight responsibility for state and county offices to monitor library services that is being shirked, when in fact, county offices of education have no such authority (except to monitor staff assignments and credentialing of teacher librarians), yet provide an array of supports.

Page 26 of the report indicates that the state and counties “are not ensuring” a minimum level of library service is being provided….” The primary character of county offices of education is that of support,however the text does not acknowledge the extent or nature of the support provided. San Bernardino County is actually doing plenty to support the use of libraries at the school, district, city, and county level.

The SBCSS provides coordinated outreach and assistance to support school library services in the 33 school districts in San Bernardino County, as well as coordinating and aligning resources with the San Bernardino County librarian to provide access to library services and resources to educators, students and families throughout the county. Because the ability to read by third grade is one of the greatest indicators of a child’s future academic performance and success in life, our countywide Library Collaborative of school and community libraries share multiple programs and resources, and a wealth of professional capacity to promote and increase family literacy and the reading proficiency of students.

Just some of the initiatives and key actions taken include:

The paragraph below is also referenced in our comment number 3.

Given this alignment of resources and array of services offered, it is of concern that the report does not include examples of the extensive work that has taken place in San Bernardino County to build a network of library services and resources between school, city and county libraries.

4

With regards to the Model School Library Standards, it may be important to make clear that the Model School Library Standards are guidance, not required or a mandate. It should be noted that the ELA/ELD California State Standards include the same requirements that are in the library standards. In alignment with these standards, county offices of education provide tremendous amounts of professional and technical development for pre-K through 12 teachers, administrators and district leadership in how to guide students to “..learn how to transform isolated bits of information into knowledge, evaluate sources, and think critically” (pg. 3, Summary).

Teachers in all content areas are also required to provide exactly this learning both in the way of knowledge, and in applied activities and projects, as part of the Common Core State Standards.

It may be important for the recommendations of the Auditor to emphasize the nature of the Local Control Funding Formula (LCFF) and Local Control Accountability Plan (LCAP) guidelines, and of the State Board LCAP template (pg. 9 recommendation to make Library Standards “part of the LCAP Process,” and pg. 28-29, 31). Following the core principle of Governor Jerry Brown’s Local Control Funding Formula, the LCAP template is designed to ensure there is a balance of local control with assurances to see that state priority areas and content standards, and local district goals for student achievement, are being met. For example, page 16 of the Report points out that “under the current model, districts decide how best to spend school funding to meet their identified needs.” Among county offices of education statewide, SBCSS was the first to develop a model that provides a multi-faceted team of experts to support districts in the cross-development of their budgets and LCAPs, and to work collaboratively with districts in continuous improvement to meet both state requirements and local priorities.

The paragraph below is also referenced in our comment number 2.

Finally, the title of the report, “School Library Services: Vague State Laws and a Lack of Monitoring Allow School Districts to Provide a Minimal Level of Library Services” is concerning as it suggests that there is a mandated monitoring requirement that is not occurring and that districts desire to provide a minimal level of library services. Also, the tone of the Report, in its entirety, would lead one to infer that compliance requirements are not being met, yet there are no statutes or regulations to monitor compliance of library services.

5

While each school district and its local governing board ultimately hold responsibility for adopting their own local policies with regards to state and federal statute, and state adopted content standards, my office is committed to serving the districts in San Bernardino County with guidance, support and best practices concerning library services for students. There are many ways to increase library services and usage. The SBCSS has found that aligning resources in a countywide collective impact approach is enhancing the effectiveness of services to students and families.

I greatly appreciate your interest in and support of public education in San Bernardino County, our schools, students and staff. I look forward to working collaboratively and positively with the State Auditor on this matter to see that all of our students receive the best access to library services and opportunities to fulfill their greatest potential.

Sincerely,

Ted Alejandre
San Bernardino County Superintendent






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE SAN BERNARDINO COUNTY SUPERINTENDENT OF SCHOOLS

To provide clarity and perspective, we are commenting on the San Bernardino County Superintendent of Schools’ (San Bernardino County Education) response to our audit. The numbers below correspond to the numbers we have placed in the margin of San Bernardino County Education’s response.

1

While preparing our draft report for publication, some page numbers shifted. Therefore, the page numbers San Bernardino County Education cites in its response do not correspond to the page numbers in our final report.

2

San Bernardino County Education states that the report’s title and tone would lead one to infer that there is a mandated monitoring requirement that is not occurring. However, as we note here and here in the Audit Results, we identified no legal requirement that county offices of education support districts in the provision of library services and we determined that county offices of education do not have express authority to assess whether districts actually provide library services. Because county offices of education have no monitoring requirement related to library services and no authority to ensure the provision of those services, we noted that county offices of education do little to ensure a minimum level of library services is provided. As we state in the Audit Results, students and teachers may receive library services from individuals who are not qualified to provide them because counties lack the authority to ensure that only certificated staff provide certain library services. Accordingly, we recommend the Legislature broaden the authority of the county offices of education to address classified staff who perform duties that require certification. Further, in the Audit Results we identified a low school district response rate to Education’s annual school library survey and here and here in the Audit Results we note weaknesses in school districts’ consideration of the Model School Library Standards for California Schools, Kindergarten Through Grade Twelve (model standards) in their local control accountability plan (LCAP) processes.

3

San Bernardino County Education states that the report inaccurately describes its Media Library Education Network (MLEN); however, we do not specifically mention the MLEN anywhere in the report. In addition, San Bernardino County Education describes a variety of initiatives and actions it has taken related to literacy; however, these examples are generally outside of the scope of our audit objectives, which are specific to school library services and teacher librarians. To address the audit scope and objectives, we describe San Bernardino County Education’s past employment of a roving teacher librarian in the Audit Results. Although San Bernardino County Education discontinued the program, we credit it for contracting with a teacher librarian to conduct free training workshops for teacher librarians and classified staff.

4

San Bernardino County Education states that the English Language Arts/English Language Development California State Standards—part of the California Common Core State Standards—include the same requirements that are in the library standards. However, as we state in the Audit Results, the common core standards’ goals overlap with fewer than half of the model standards’ 64 goals for students in grades nine through 12. In addition, the model standards provide other specific guidance related to library services that is not included in the common core standards, such as goals related to library staffing and resources. In addition, San Bernardino County Education states that it may be important to make clear that the model standards are guidance, not required or a mandate. However, we already note this fact here, here, and here in the Audit Results.

5

San Bernardino County Education did not specifically address our recommendation related to strengthening school library programs in its county. However, San Bernardino County Education states that it is committed to serving its districts with guidance, support, and best practices concerning library services for students. Thus, we look forward to San Bernardino County Education’s 60-day response to clarify the specific actions it is taking to provide guidance to its school districts regarding the use of teacher librarians, completion of the annual school library survey, and consideration of the model standards as part of the LCAP process.



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San Juan Unified School District

October 27, 2016

Elaine M. Howle, CPA
621 Capitol Mall
Sacramento, CA 95814

Re: San Juan Unified School District Library Service Audit Report 2016-112

Dear Ms. Howle;

San Juan Unified School District is committed to providing high quality educational services and supports for students and families to ensure that each student is college, career and citizenship ready and graduates on time. We strongly believe in holding every student at our 63 schools to high expectations as outlined in state content and performance standards. We also strongly believe in providing the necessary services and supports to maximize each student’s success. Our Local Control and Accountability Plan (LCAP) and the adopted district budget outline how we support our schools and students in reaching the identified goals.

Based upon the findings and recommendations in the School Library Service Audit Report, we will be reviewing San Juan’s library services to identify how to support all of our students in developing information literacy and meeting standards in all other content areas. Staff has now been identified and assigned with specific responsibilities around support of teacher librarians and other library staff. Additionally, Board Policy 6163.1 Libraries/Media Centers, as well as the related Administrative Regulations, will be reviewed and updated during the 2016-17 school year using the California School Board Association’s model board policy as a guide. Once in place this Board Policy will form the basis of improvement work in the area of library services.

Based on a review of current practices in relationship to the revised Board Policy and Administrative Regulations we will prioritize needs and allocate resources, as available, to strengthen library services within district schools. Revised processes which support increased services will be implemented. I am confident these changes will increase the library services for staff and students in San Juan Unified School District. Enclosed please find the responses to State Audit Report 2016-112.

Sincerely,

Donna O’Neil, Ed.D.
Associate Superintendent of Schools and Support Services



Recommendation 1

Ensure that teacher librarians are involved in the selection of library materials at each school

Response

San Juan Unified School District agrees with this recommendation. Identified district staff will facilitate collaboration among library staff across grade spans, drawing on the knowledge and expertise of teacher librarians to provide input in the selection of library materials for schools. Board Policy and Administrative Regulation 6163.1 will be reviewed and updated to increase guidance on the library material selection process. Once the new policy and regulations are in place, an ongoing process will be established and implemented to ensure compliance with the policy.

Recommendation 2

Consider ways to leverage the teacher librarians that they already employ to offer a broader range of services to all grade levels

Response

San Juan Unified School District agrees with the recommendation and will support collaboration among all library staff to capitalize on the expertise and training of teacher librarians. Identified district staff will facilitate collaboration among library staff across grade spans, drawing on the knowledge and expertise of teacher librarians to guide the expansion of library services, especially at the elementary and middle school levels.

Recommendation 3

Use the model standards to assess the needs of their school library programs and address any identified needs during their LCAP process

Response

San Juan Unified School District agrees with the recommendation. District staff will be assigned to support this process in collaboration with library staff across the district. The intent will be to deepen understanding of the model standards, to assess the extent to which the standards are being met, and to make recommendations on steps necessary to increase alignment with the model standards. This analysis will considered during the LCAP revision, in order to prioritize needs and allocate resources, as available.

Recommendation 4

Require their schools to participate in Education’s annual school library survey

Response

San Juan’s rate of completion of the most recent survey was 85.5%, the highest cited in the report. If the request for completion of the survey or notification of the survey comes to a district office employee it will be possible to get full participation. A designee will be assigned in future years to communicate about the survey and follow up to ensure full participation by district schools.



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Tulare County Office of Education

October 27, 2016

Elaine M. Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Dear Ms. Howle:

The Tulare County Office of Education appreciates the opportunity to respond to the recommendations outlined in California State Audit Report No. 2016-112.

Recommendation 1: “should provide guidance to their school districts on using teacher librarians for the provision of library services.”

Response: Tulare County Office of Education (TCOE) agrees with this recommendation and will continue to provide guidance to districts. Activities we have previously engaged in toward this end include the following: April 2016, TCOE’s Educational Resource Services library media supervisor presented at a regional Learning and Leadership Forum. The library media supervisor addressed the value and importance of employing a teacher librarian or contracting with Tulare County Office of Education for library services. In addition, the ERS library media supervisor’s office sends a monthly newsletter to contracting administrators and teachers promoting the services provided by the library media supervisor, and the print and digital resources available through the ERS library. Lastly, the library media supervisor has contacted school districts that do not employ a teacher librarian in an effort to encourage them to employ a teacher librarian for their district or to contract with Tulare County Office of Education for teacher librarian services and print and digital resources.

Recommendation 2: “should provide guidance to their school districts on completing Education’s annual school library survey”

Response: Tulare County Office of Education (TCOE) agrees with this recommendation and will continue to provide guidance to districts. Activities we will conduct to address this recommendation include the following: To address the low number of respondents, 23.2% of schools in Tulare County completed the survey for the 2014-2015, TCOE’s library media supervisor will take advantage of the March 13, 2017 bimonthly library paraprofessional meeting to support every attendee with completing the annual school library survey prior to the April 30, 2017 deadline. As was done in April 2016, she will craft a follow-up email in early April to send to both school administrators and library paraprofessional staff who have not yet completed the survey, encourage them to do so, and to offer her support in completing the survey.

Recommendation 3: “should provide guidance to their school districts on identifying the needs of their school library programs by using the model standards as part of their LCAP process.”

Response: Tulare County Office of Education (TCOE) agrees with this recommendation and will continue to provide guidance to districts. Activities we have previously engaged in toward this end include the following: April 2016, TCOE’s Educational Resource Services library media supervisor presented at a regional Learning and Leadership Forum. The focus of these ongoing forums is development of district’s Local Control Accountability Plans (LCAP.) The library media supervisor addressed the value and importance of employing a teacher librarian or contracting with TCOE for library services. Additionally, TCOE’s Educational Resource Services Library has a link on their website for administrators with information on: services provided by the ERS library, CDE’s adopted Model School Library Standards, the role of the school librarian in implementing Common Core State Standards, as well as research and statistics on the educational impact of strong school library programs. Lastly, Model School Library Standards training was provided to district and county school boards at our local School Boards Summit (Fall Institute 2015) so that informed decisions on LCAP expenditures related to library services could be made at the local level. These considerations will continue to be incorporated into TCOE's individualized district LCAP development technical assistance provided by Martin Frolli, TCOE Leadership and Support Services Director.

If you have any questions regarding Tulare County Office of Education’s comments or actions, please contact Debra Lockwood, Library Media Supervisor, by email at debral@tcoe.org, or by phone at 559-651-3042 ext. 3310.

Sincerely,

Charlene Stringham
Assistant Superintendent, Instructional Services
Tulare County Office of Education



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Woodlake Unified School District

October 27, 2016

Elaine M. Howle
California State Auditor
Capital Mall, Suite 300
Sacramento, CA 95814

Dear Ms. Howle:

Woodlake Unified School District is committed to providing outstanding educational opportunities to all of its students with the goal of making a generational change within our community. We use the continuous improvement process as a means for achieving this goal. Literacy, including information literacy, is a critical component of our mission and is taught throughout the instructional day.

We currently contract with the Tulare County Office of Education for library services and will continue to do so. We will work with our Library consultant more closely as we move forward so our district can provide our students with every opportunity to have success during their K-12 experience and in their post-secondary endeavors. We understand that we live in an information age and that location and evaluation of information is critical to social and economic wellbeing.

In support of this effort, the district is working to provide our students with a device and access to filtered internet at home to level the playing field. We will utilize the model library standards as a lever as we implement changes to our instructional program that will maximize this investment.

Enclosed, please find our responses to the State Audit Report 2016-112.

Sincerely,

Drew Sorensen
Superintendent

Recommendation No. 1

Ensure that Teacher Librarians are involved in the selection of library resources.

Woodlake Unified agrees with this recommendation.

Woodlake Unified will ensure that our school sites coordinate future library purchases with the teacher librarian at the Tulare County Office of Education. This includes utilizing the teacher librarian’s suggested list and consulting with the teacher librarian prior to submitting an order for materials other than replacement titles.

Recommendation No.2

Consider ways to leverage the teacher librarians that we already employ to offer a broader range of services to all grade levels.

Woodlake Unified agrees with this recommendation.

Woodlake Unified utilizes the services of the Tulare County Office of Education’s library services. District staff will meet with the Teacher Librarian at the end of each year to plan services for the following year to ensure students at each grade level have access to Library services that are based on the model standards with improvement over time as the goal.

Recommendation No. 3

Use the model standards to assess the needs of their school library programs and address any identified needs during the LCAP process.

1

Woodlake Unified disagrees with this finding. The LCAP template does not specify that the model standards are required and stating that information in the frequently asked questions should be considered a mandate is unfair to districts.

In spite of our disagreement, Woodlake Unified will work with the teacher librarian at the Tulare County Office of Education to assess the implementation of the model standards at our school sites with continuous improvement as the goal. Training in the model standards for both classified library technicians, site administration, as well as teacher leaders will be included as part of the needs assessment. The district will work to include the model standards implementation into the LCAP process.

Recommendation No. 4

Require schools to participate in Education’s annual school library survey.

Woodlake Unified agrees with this recommendation.

District staff will require each site administration to meet with library staff at their site to complete the survey and report the date and time of submission to the Assistant Superintendent.






Comments

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE WOODLAKE UNIFIED SCHOOL DISTRICT

To provide clarity and perspective, we are commenting on the Woodlake Unified School District’s (Woodlake Unified) response to our audit. The number below corresponds to the number we have placed in the margin of Woodlake Unified’s response.

1

Woodlake Unified mischaracterizes our discussion of the model standards in relation to the local control accountability plan (LCAP) requirements. We state in the Audit Results, although the California Department of Education identifies the Model School Library Standards for California Public Schools, Kindergarten Through Grade Twelve (model standards) as one of the State’s academic content and performance standards, the LCAP template does not list any of the standards that school districts must address. We further conclude in the Audit Results that without additional guidance, school districts may not consider using the model standards during the LCAP process to identify weaknesses in their library programs and to develop goals to address those needs. We stand by our recommendation on page 33 that to strengthen their library programs school districts should use the model standards to assess the needs of their school library programs and address any identified needs during the LCAP process. Although Woodlake Unified indicates that it disagrees with our finding, it states that it will implement our recommendation.




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