UC Berkeley

Federal Program Monitoring (FPM) is California’s current education compliance monitoring process. Roughly 120 local educational agencies (LEAs) each year are selected to receive a FPM review—half on-site and half online. Through FPM, the California Department of Education (CDE) reviews a variety of categorical programs, including the English learner (EL) program, for compliance with state and federal mandates. LEAs found to be non-compliant (NC) in one or more categorical programs are required to resolve the NC findings within certain timelines or, potentially, face state fiscal sanctions.

This comparative case study explored the responses to FPM by district leaders from two urban school districts selected via a purposive sampling approach. In particular, this study investigated whether LEAs leverage FPM to improve the provision of services to English learners and, in particular, English language development (ELD) instruction.

My conceptual framework posits that the different responses by district leaders to the various forms of education accountability regimes I identify can be explained, in part, to their position on various conceptions that, ultimately, influence their willingness and their capacity—integrity serving as a mitigating factor. These responses that can be grouped into three categories: leveraged compliance, contrived compliance, or non-compliance.

As predicted by my conceptual framework, I found contrasting findings across the two districts for predictable reasons, or, theoretical replication. The Puente Verde USD had a high level of willingness to be responsive to FPM. In comparison, Windy Hills USD’s ideological stance on ELD—incongruent with the CDE’s—coupled with their integrity to do what they felt was the right thing, inhibited their willingness to be as responsive to FPM. Additionally, whilst both LEAs had relatively high levels of capacity to implement EL programs, Windy Hills’ lower absorptive capacity constrained further capacity building.

Although compliance monitoring, like FPM, is often seen as a bureaucratic exercise, some LEAs are able to seize the opportunity to leverage it to improve services, while others, even when possessing relatively high levels of capacity may not. Oftentimes, compliance with FPM is seen as a simple bimodal response. What this study found is that it is much more nuanced.