Report 2016-129 Recommendation 3 Responses

Report 2016-129: K-12 High Speed Network: Improved Budgeting, Greater Transparency, and Increased Oversight Are Needed to Ensure That the Network Is Providing Reliable Services at the Lowest Cost to the State (Release Date: May 2017)

Recommendation #3 To: Imperial County Office of Education

To ensure that its projected program costs are as accurate as possible, ICOE should institute by November 2017 a formal practice for reviewing its budget planning document against its current network design plans and correct any inaccuracies before finalizing and submitting its budget.

Annual Follow-Up Agency Response From October 2018

ICOE began implementing new practices with regard to budget review, review of network design plans and budget submission in October 2017. These practices continued through 2018 with predecessor steps rolling forward to earlier dates on the calendar for activities such as data collection (Jan-May), assessment of node site needs (May-June), developing a list of node sites under consideration for upgrade (June), and posting of E-rate required documents for bidding purposes (August). Memorializing new protocols as a written policy has now also occurred with said policy included on the K12HSN website for public access at The policy is being provided via email to Mark Reinardy per instructions. A PDF file depicting the project management dashboard related to these steps is also being provided.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

As ICOE indicates in its response, it asserted during earlier status reports that it had implemented this recommendation. However, the documentation ICOE submitted to support its claim was limited to the calendar schedule by which it determines its program, and thus budgetary needs. The audit findings that drove this recommendation were not the consequence of shortcomings in that process (which we addressed through recommendation #6), but rather insufficient processes for ensuring that the amounts in its budget submission to the State accurately reflected expected costs.

Along with its current response, ICOE provided documentation outlining not only the timeline for developing the annual K12HSN budget, but also the roles and responsibilities of specific staff in performing multiple levels of review of budget-related documentation. Diligently adhering to these protocols will assist ICOE in its efforts to increase the accuracy of its budget proposal for the K12HSN program.

1-Year Agency Response

ICOE has developed and posted the K12 Node Site Upgrade Decision process that aligns with required budget documents for presentation to Education. Inputs to the development of the process include the Network Implementation Committee, CENIC, the California Department of Education and internal processing. This practice is currently in place and will be revisited annually during the October/November time frame in alignment with recommendation #2.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

ICOE's response speaks to network upgrade decision-making issues we address in Recommendation 6, as well as the ultimate format of its budget presentations to the State, which we address in Recommendation 2. However, the response does not include information about how ICOE ensures that the cost information derived from its network planning decisions is accurately reflected in its proposed budget. Our audit found significant inconsistencies between ICOE's planned activities with the network and the costs included in its budget documents.

When we followed up with ICOE, it provided information about an electronic application it is using to memorialize the review of relevant documents. However, it did not provide any documentation about how that review is to take place or who is responsible for it--key elements of our recommendation that we emphasized in our previous evaluation of ICOE's response to this recommendation.

6-Month Agency Response

ICOE has aligned planning documents to match the proposed budget documents presented to Education. This practice is currently in place and will be revisited annually during the October/November time frame in alignment with recommendation #2.

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

ICOE provided up-to-date versions of the planning documents its used to create its anticipated budget request for the 2018-19 fiscal year and explained that, subsequent to our review, K12HSN's fiscal manager is now assisting network staff with the creation of those documents and is reviewing them to ensure the documents accurately reflect anticipated network costs. However, ICOE has yet to memorialize this process either as a formal program protocol or in the duty statements of the staff positions involved. We recommended a formal implementation of this review process in order to help ensure that it occurs consistently and to better establish accountability for the accuracy of ICOE's budget submissions.

60-Day Agency Response

A new process will be utilized when the request for proposals closes. The process will involve a comparison of the pricing sheets submitted by proposers against network design layouts. The process will permit K12HSN staff to confirm costs proposed by vendors, ring designs, and wherever possible, achieving carrier and hub site diversity. The process will occur in October of every year and involve comparing various scenarios against budgeting documents.

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

All Recommendations in 2016-129

Agency responses received are posted verbatim.