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Report Number: 2016-114

College Readiness of California's High School Students
The State Can Better Prepare Students for College by Adopting New Strategies and Increasing Oversight

Responses to the Audit

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California Department of Education

February 13, 2017

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

Subject: College Readiness of California High School Students – By Adopting New Strategies and Increasing Oversight, California Can Better Prepare Its Students for College,” Report No. 2016‑114, February 2017

The California Department of Education (Education) appreciates the opportunity to comment on the recommendation outlined in the California State Auditor’s (CSA) Audit Report No. 2016‑114, titled: “College Readiness of California High School Students – By Adopting New Strategies and Increasing Oversight, California Can Better Prepare Its Students for College.”

Recommendation No. 1:

To comply with existing law and ensure that students receive sufficient access to college preparatory coursework, Education should provide training and guidance to districts throughout the State on the creation and application of appropriate district and school-level access analyses.

Education's Comments


Education does not concur. The CSA’s recommendation is inconsistent with the framework established by the Legislature’s adoption of the Local Control Funding Formula (LCFF) in 2013. The LCFF focuses on local assessment of need and local decision-making to address those needs around eight state priorities, including student achievement as measured by college readiness indicators and access to a broad course of study. As part of the LCFF, school districts, county offices of education and charter schools are required to develop, adopt, and annually update a three-year Local Control and Accountability Plan using a template adopted by the California State Board of Education.

Education is in compliance with California Education Code Section 66204(a), which directs the State Superintendent of Public Instruction to:

  1. assist all school districts to ensure that all public high school pupils have access to a core curriculum that meets the admission requirements of the University of California and the California State University;

  2. advise school districts that maintain high schools about the importance of making readily available to each high school pupil the current list of courses offered by the school attended by that pupil that are certified by the University of California as meeting admissions requirements.

The auditors subjectively report that, “Education currently provides only minimal assistance to districts…” However, on the contrary, Education provided the auditors with evidence demonstrating substantial guidance and assistance to districts over a multi‑year period, including the period covered in the audit. This evidence included a letter dated September 1, 2016, to local educational agencies (LEAs) concerning the $200 million College Readiness Block Grant (see; a college readiness Web page (see; and curriculum framework guidance on developing secondary courses. In addition, Education has program staff assigned to provide districts with ongoing technical assistance and guidance related to a variety of college preparatory course topics.


Education also provided LEAs with significant information regarding the state’s assessment system (California Assessment for Student Performance and Progress), which focuses on measuring student’s preparedness for college and career. This assessment system includes a measurement of grade eleven students’ readiness for access to the California State University and California Community College systems, known as the Early Assessment Program.

Furthermore, during the audit period from 2013 to 2016, Education implemented, on a statewide basis, an unprecedented $1.6 billion investment in expanding student access to career and college opportunities in the form of the California Career Pathways Trust, the Career Technical Education Incentive Grant, and the College Readiness Block Grant. As part of implementing these three legislatively authorized initiatives, Education provided districts with ongoing technical assistance and guidance as well as professional development and other informational resources.


The auditors also report that, “Education is aware of some instances of high schools offering limited rigorous courses,” citing as evidence the State Superintendent’s letter to LEAs dated September 26, 2016,, indicating that 40 percent of high schools offered Advanced Placement (AP) courses in fewer than five subject areas in academic year 2014–15. Education notes that this letter also provided 19 resources to help districts increase their offerings, and included the option for districts to contact Education directly for support.

Going forward, Education will continue to provide assistance to districts as required by Education Code Section 66204(a). For example, the new State Accountability and Continuous Improvement System, which was being developed during the audit period, includes the State Board of Education’s adoption of a College and Career Indicator.

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


Michelle Zumot
Chief Deputy Superintendent of Public Instruction




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


Education misunderstands our recommendation. As Education acknowledges, the superintendent of public instruction has a specified duty in assisting school districts in ensuring that all public high school pupils have access to college preparatory coursework. Moreover, as we describe in Chapter 2, as part of the change to school funding framework established by the local control funding formula (funding formula), local educational agencies (LEAs) must complete and update annually Local Control and Accountability Plans (accountability plans). These accountability plans must include specific information regarding student achievement as measured by the rate of college preparatory coursework completion, among other metrics, as we state in Chapter 2. However, there is nothing in state law or regulation relating to the funding formula that precludes Education from implementing our recommendation. Indeed, rather than being “inconsistent with the framework,” we think our recommendation furthers the Legislature’s intent in supporting this state priority.


Education has subjectively omitted the second portion of our sentence. Specifically, in Chapter 2, we state that Education provides minimal assistance to districts to ensure that students have access to college preparatory coursework. None of the examples that Education cites relate to ensuring that districts provide sufficient college preparatory coursework access.


We note that Education’s own administrator of the college preparation and postsecondary programs office acknowledged Education does not offer formal assistance to districts related to access to college preparatory coursework; instead it directs the districts to contact the University of California. The administrator further stated that Education could have a role in assessing the sufficiency of the access that districts provide; however, he explained Education currently has no guidelines and no resources associated with this issue. Thus, even though Education indicates that it has staff assigned to provide districts with ongoing assistance, this assistance does not relate to college preparatory coursework access.


We fail to see the merit of Education’s argument. The information provided to LEAs related to the California Assessment of Student Performance and Progress (CAASPP) does not relate to assisting districts to ensure they provide sufficient access to college preparatory coursework. According to Education’s website, CAASPP identifies a student’s ability to perform college‑level work in English and mathematics. It is unclear how this examination or the resulting achievement level given to each student in several subject areas helps ensure that districts are providing access to college preparatory coursework needed to enter the State’s public university sytems.


As noted previously, Education specified in its September 26, 2016 letter that it provided these 19 websites only as a convenience, and that their inclusion did not imply its endorsement. We maintain that one letter, which Education sent after our audit began, about advanced placement courses with an attached list of web addresses does not constitute adequate assistance to districts to ensure they provide sufficient access to college preparatory courses, especially given that each of the three districts we reviewed lacked data and processes to demonstrate they offered enough college preparatory courses in each of the years we reviewed.

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Coachella Valley Unified School District
(Emailed Response)


CVUSD has taken stringent measures in the past 3 years to address not only graduation, but A-G access to give rise to improving completion rates. Our graduation requirements, processes, and coursework has seen significant changes to grant our students with access and opportunities to establish A-G status. CVUSD does not have an access issue but does continue to work on academic achievement issues which are effecting students’ success in A-G completion. The audit focused primarily on past practices before the aforementioned changes came to practice. CVUSD will continue to build personnel capacity and programs to help foster improvements in both student achievement and system processes in support of students.

Thank you.

Jason B. Angle, Ed.D.
Assistant Superintendent
Educational Services Division
Coachella Valley Unified School District



To provide clarity and perspective, we are commenting on the response to our audit report from Coachella Valley Unified School District (Coachella). The number below corresponds with the number we have placed in the margin of Coachella's response.


Although the audit found various issues with Coachella’s past practices, our recommendations will help ensure ongoing success related to college preparatory coursework access and completion. We look forward to reviewing the evidence of the improvements that Coachella asserts it has made in its response.

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Stockton Unified School District

February 15, 2017

TO: Ms. Aaron Fellner
Auditor, California Department of Education
FROM: Robert Sahli
Executive Director, Curriculum and Professional Development
SUBJECT: A-G Audit Response

Stockton Unified School District (SUSD) is continually working to improve services to students in all areas including access to and successful completion of A-G courses. SUSD has course offerings at all of its high schools that will provide a complete menu of courses necessary to qualify for UC/CSU admission provided the students successfully pass their courses in timelines established or commit to successful completion of credit recovery options.

SUSD’s graduation requirements, at the minimum level, do not meet the requirements of A-G in the areas of Mathematics, World Language and Visual and Performing Arts. However, all students are encouraged to pursue meeting A-G. Since many students fall short in the areas listed above, the SUSD overall completion of A-G is negatively impacted. The graduation requirements do meet criteria for admission to community colleges and the majority of SUSD graduates who continue in an academic postsecondary pathway choose to attend the local college, Delta Community College. SUSD could choose to have graduation requirements mirror A-G requirements, but this would negatively impact graduation rates and those who do not choose to pursue a four year college pathway immediately after high school.

Over the course of the past five years, since implementation of a new Student Information System (Synergy), much work has been completed to correct errors in course codes, titles, and the related flagging of courses for A-G. During this timeframe, UCOP has also modified its processes from decentralized submission to centralized which will reduce errors. While there is a process in place at all schools for counselors to assist students in building their high school course pathways, SUSD is formulating a more formal process of documenting students’ progress through their battery of courses to graduation. This process includes the creation of a new comprehensive counseling handbook and the use of an on-track to graduate software application. SUSD recently received a college and career block grant that will allow for hiring of a staff member to oversee district college and career efforts.

SUSD has undertaken several LCAP changes since the 2014-2015 LCAP plan year. In 2015, new staff was assigned specifically to the LCAP. There are issues with the LCAP system established by the State of California that SUSD must work under. Actions and services instituted through the LCAP cannot be fully measured for effectiveness until the students receiving the services graduate. Information to determine if an action or service is “effective” is dependent on last year’s data for this year’s activities and the determination of effectiveness is therefore skewed. SUSD is proactive in assessing previous LCAPs to gain insight to better plan and implement services to ensure all students, including unduplicated populations, are receiving services to be college and career ready.

SUSD will continue to remove obstacles and improve opportunities for students as they negotiate a pathway to gradation and their choice of a college or career.

Cc: Eliseo Dávalos, Superintendent
Tom Anderson, Assistant Superintendent

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