Report 2016-117 All Recommendation Responses

Report 2016-117: Alliance College-Ready Public Schools: The Nonprofit Did Not Spend Public Funds or Divert Classroom Resources in Response to Unionization Efforts (Release Date: April 2017)

Recommendation #1 To: Alliance College-Ready Public Schools

To ensure it complies with federal laws regarding student privacy, Alliance should document its revised process for collecting, tracking, and monitoring the list of Alliance students and families who have opted out of sharing their directory information with third parties.

60-Day Agency Response

Alliance developed a memo, which documented its revised process for collecting, tracking, and monitoring the list of Alliance students and families who have opted-out of sharing their directory information with third parties. This memo was shared with staff and teams that play a role in the process, and has also been saved on a shared drive where staff can access it.

California State Auditor's Assessment of 60-Day Status: Fully Implemented

Alliance College-Ready Public Schools (Alliance) documented its process for annually collecting, tracking, and monitoring the list of Alliance students and families who have opted out of sharing their directory information with third parties.

Recommendation #2 To: Alliance College-Ready Public Schools

Alliance should standardize its data-sharing agreements so that each agreement contains robust and specific language regarding data security and the confidentiality of the data being shared.

60-Day Agency Response

Alliance College-Ready Public Schools worked with legal counsel to develop a template data-sharing agreement with robust and specific language for use when Alliance works with third-parties to share data, as well as additional standard, robust, and specific data-sharing language that was incorporated into Alliance's standard contacting template. Both templates are available on Alliance's procurement web site, which is what staff members use when they are going through the contracting process. Staff who work with data on a regular basis were also instructed to have Alliance's legal counsel review all draft third-party contracts that include data-sharing language to ensure that it meets Alliance's standards before the contract is finalized.

California State Auditor's Assessment of 60-Day Status: Fully Implemented

The Alliance College-Ready Public Schools (Alliance) developed a contracting template for data-sharing agreements that includes specific language regarding data security and the confidentiality (including FERPA requirements) for use when Alliance works with third-parties to share data.

Recommendation #3 To: Alliance College-Ready Public Schools

The Alliance home office should update and formalize its procurement policies and procedures manual to establish competitive bidding thresholds for the procurement of goods and services, and it should provide adequate training to appropriate staff before the start of the 2017-18 school year.

6-Month Agency Response

Alliance has updated and formalized its procurement policies and procedures manual and appendix to establish competitive bidding thresholds for the procurement of goods and services. Alliance has trained all required staff at the home office and schools, and implementation of these policies and procedures is underway.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

Alliance College-Ready Public Schools (Alliance) provided its July 2017 Fiscal Policies and Procedures manual that included competitive bidding thresholds for the procurement of goods and services. Alliance also provided documentation demonstrating staff attended training for these policies and procedures.

60-Day Agency Response

Alliance has updated and formalized its procurement policies and procedures manual and appendix to establish competitive bidding thresholds for the procurement of goods and services. Alliance is in the process of training staff at the home office and schools and will be able to finish training for all staff in the beginning of July 2017.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #4 To: Alliance College-Ready Public Schools

The Alliance home office should update and formalize it's procurement policies and procedures manual to require both the Alliance home office and charter schools to retain contract records for at least five years, and it should provide adequate training to appropriate staff before the start of the 2017-18 school year.

6-Month Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to require both the Alliance home office and charter schools to retain contract records for at least six years. Alliance has trained all required staff at the home office and schools, and implementation of these policies and procedures is underway.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

Alliance College-Ready Public Schools (Alliance) provided its July 2017 Fiscal Policies and Procedures manual that included Alliance home office's and charter schools' procurement record retention policies. Alliance also provided documentation demonstrating staff attended training for these policies and procedures.

60-Day Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to require both the Alliance home office and charter schools to retain contract records for at least six years. Training will be complete for all staff at the beginning of July 2017.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: Alliance College-Ready Public Schools

The Alliance home office should update and formalize it's procurement policies and procedures manual to establish adequate segregation of duties for procurements to mitigate the risk of fraud and abuse, and it should provide adequate training to appropriate staff before the start of the 2017-18 school year.

6-Month Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to establish adequate segregation of duties for procurement. Alliance has trained all required staff at the home office and schools, and implementation of these policies and procedures is underway.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

Alliance College-Ready Public Schools (Alliance) provided its July 2017 Fiscal Policies and Procedures manual that included segregation of duties policies for procurement at Alliance home office and Alliance charter schools. Alliance also provided documentation demonstrating staff attended training for these policies and procedures.

60-Day Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to establish adequate segregation of duties for procurement. Training will be complete for all staff at the beginning of July 2017.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #6 To: Alliance College-Ready Public Schools

The Alliance home office should update and formalize it's procurement policies and procedures manual to obtain and retain vendor conflict-of-interest forms, and it should provide adequate training to appropriate staff before the start of the 2017-18 school year.

6-Month Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to obtain and retain vendor conflict-of-interest forms. Alliance has trained all required staff at the home office and schools, and implementation of these policies and procedures is underway.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

Alliance College-Ready Public Schools (Alliance) provided its July 2017 Fiscal Policies and Procedures manual that included procurement policies regarding obtaining and retaining vendor conflict-of-interest forms. Alliance also provided documentation demonstrating staff attended training for these policies and procedures.

60-Day Agency Response

Alliance has updated and formalized its procurement policies and procedures manual to obtain and retain vendor conflict-of-interest forms. Training will be complete for all staff at the beginning of July 2017.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2016-117

Agency responses received are posted verbatim.