Preparing for the California ELO-P Audit

From registration forms to staff ratios, successful ELO-P audits depend on one thing: preparation. When selected for review, California expanded learning programs must demonstrate compliance with detailed operational standards - a task that can feel overwhelming without the right systems in place.

Let's break down what you need to know about ELO-P audits, drawing from California Department of Education guidelines and official audit requirements.

The Basics of ELO-P Audits

ELO-P programs are subject to annual audits as part of the broader K-12 Local Education Agency audit process, with specific attention paid to how funding supports compliance and program success. According to the Audit Guide (General Provisions), these audits must be conducted in accordance with:

• Standards generally accepted in the United States of America
• Government Auditing Standards (Yellow Book)
• Federal audit regulations (Part 200 of Title 2 of the Code of Federal Regulations)

Your program will be included in the annual audit if your LEA receives ELO-P funding or Home-to-School Transportation Reimbursement (Audit Guide, Section DZ). This audit covers one fiscal year and is designed to ensure programs are meeting both operational and financial requirements.

Key Areas of Focus

According to the Audit Guide (Section DZ), auditors must examine several critical aspects of your program, with particular focus on program access and implementation requirements.

Program Access and Implementation

One of the primary focuses of the audit is verifying that your program is serving students as required by the funding regulations. For programs funded at Rate 1, auditors will verify that you've offered the program to all students in classroom-based instructional programs from TK through 6th grade. For Rate 2 funding, they'll check that you've offered the program to all unduplicated pupils in those same grades (Audit Guide, Section DZ, procedures 2-5).

Beyond program access, auditors carefully examine your daily operations. According to Education Code section 46120(b)(1)(A) as referenced in the Audit Guide (Section DZ, procedure 6), your program must provide nine hours of combined time when added to the regular school day. Additionally, your program must operate for at least 30 non-schooldays (Education Code section 46120(b)(1)(B)).

Staff-to-student ratios are another critical component. According to Education Code section 46120(b)(2)(D), programs must maintain:

• A 10:1 ratio for transitional kindergarten and kindergarten students
• A 20:1 ratio for all other grade levels

Documentation and Compliance

The audit process relies heavily on thorough documentation. According to Education Code section 46120(b)(2), your program must demonstrate that it provides:

• An educational and literacy element where tutoring or homework assistance is provided
• An educational enrichment element
• Programs aligned with regular school day content

Staff qualifications and training documentation is equally important. The Audit Guide (Section DZ, procedure 9(c)) specifies that auditors will verify that all program staff and volunteers have completed required background checks and health screenings, as mandated by Education Code section 8483.4.

After school program management platforms like Attendly can streamline this documentation process by providing:

• Digital attendance tracking that aligns with state reporting requirements
• Program scheduling tools that help with verifying the nine-hour day requirement
• Staff assignment tracking to monitor ratios
• Secure data storage for documentation

The Audit Process

When auditors review your program, they follow a structured process outlined in the Audit Guide (Report Components). If they identify any areas of concern, they must provide:

• A clear statement of the requirement not met
• Evidence indicating non-compliance
• Steps required to demonstrate compliance

Your program will have the opportunity to respond to any findings through a corrective action plan, which must be included in the final audit report (Audit Guide, Report Components, Section 6).

Suggested Organization for the Audit

While not specifically required by the Audit Guide, having organized records will speed up the process:

• Simple File Structure:
  • Keep a central folder (physical or digital) labeled “ELO-P Audit” for the given year.
  • Sub-folders (or sections) can be:
    • Calendars and Schedules (school calendars, bell schedules, ELO-P daily/weekly schedules)
    • Enrollment and Registration (registration forms, master roster)
    • Staffing Documentation (staff rosters, ratio calculations, training/clearance records)
    • Program Content (brief descriptions or outlines of educational/literacy and enrichment activities)
    • Third-Party Contracts (if any)
    • Transportation Documents (bus schedules, if applicable)
• No Need for Extended Justifications: The auditors do not require extensive narrative explanations, internal monitoring documents, financial ledgers, board minutes, or internal memos on ELO-P operations. Stick to what the Audit Guide requests.
• Basic Check Before the Auditor Arrives:
  • Verify the ratio calculations are correct and easy to demonstrate.
  • Ensure all enrollment forms are complete and signed.
  • Confirm the documented hours and days of operation align with ELO-P requirements.
  • Check that staff have required clearance and training documentation easily accessible.

Common Pitfalls to Avoid

As you prepare for the California ELO-P audit, be aware of these common pitfalls that can hinder your compliance efforts. Getting ahead of these issues can make the audit process smoother and demonstrate your program's adherence to the required standards. Here are some key areas to focus on:

• Missing or Unsigned Registration Forms: Make sure every student counted in the program has a corresponding signed registration form.
• Incorrect Hours or Missing Days: Check that your calendar and program schedule clearly reflect the required number of hours per day and non-school days.
• Unclear Staffing Records: Ensure it’s clear which staff members were present on each day and that they meet the ratio requirements. Maintain simple attendance or staffing assignments logs.
• Insufficient Evidence of Required Components: Briefly outline program activities so auditors can see educational/literacy and enrichment offerings are indeed part of the daily schedule.
• Inaccurate Attendance Records: Records should accurately show which students attended each day, aligning with the master enrollment list and supporting compliance with program requirements.

Final Thoughts on Preparing for the California ELO-P Audit

While audits can seem daunting, understanding the process and maintaining proper documentation throughout the year makes them manageable. Focus on implementing strong systems for tracking attendance, maintaining program schedules, and documenting staff qualifications. The goal of these audits is to ensure that California's expanded learning programs are providing high-quality services to the students who need them most.