• Read our original report here.

• On September 12, the CCA Foundation released a rebuttal to our report, stating that our claims were untrue.

• After the publication of our work in the San Diego Union Tribune, the CCA Foundation released a follow-up to their original statement on September 15.

• The Foundation’s defense for not reporting Executive Director salaries is false and can be easily disproved by the very source they cited.

• The Foundation did not provide enough details regarding the nature of “Other Program Expenses”. We believe that the organization should release a full itemized list of every type of purchase that fell under this mysterious expense.

• The Foundation fails to address why the 25% fee charged on donations is more than double the rate at any other high school in the district, and they neglect to mention that an arbitrary end-of-year fee on donations is taken on top of the initial 25%.

• A former CCA Foundation president has criticized the school’s response to the report, while also alleging that the former Executive Director ignored concerns and attempted to remove any Foundation board members that disagreed with her.

Click here for the Google Document version of our update.

By: Ravens for Transparency

contact@ravensfortransparency.org

ravensfortransparency.org

Introduction

On September 12, the CCA Foundation released a rebuttal to our report detailing the shady practices within their organization. We believe that the Foundation’s arguments are largely without merit, and we will deconstruct their claims in this response.

We would like to mention that the Foundation did not reach out to us for comment or clarification before publishing their rebuttal, and that they did not provide a link to our report even though they referenced it directly and claimed it was entirely dishonest. It appears that they chose not to live up to the standards of due diligence and professional courtesy that they claim to expect from us.

Additionally, the Foundation has also released a follow-up where they imply that our goal was to attack the volunteers who work with the Foundation. This claim is untrue, and it is evident from reading our report that our criticisms were of Foundation’s policies and of its former Executive Director, who was paid over $150,000 last year, rather than volunteers.

Missing Salary Disclosures

As we stated in our previous report, the Foundation did not report Executive Director salaries from 2015-2020. The CCA Foundation justified this as stated:

“Per the IRS guidelines, the reporting of salaries in Part VII of the Form 990 is required only for officers, directors, trustees, and other key individuals if their annual salary in a given fiscal year is greater than $150,000.” 

In other words, the Foundation stated that their Executive Director was classified as a “key employee”, which has a $150,000 compensation threshold for required reporting. They reasoned that since she was paid under $150,000 during those years, not reporting salaries of the Executive Director was not illegal.

However, the CCA Foundation’s justification can be immediately disproved by the very source they cited to support their defense.

According to Part VII, Section A of the IRS’s 2023 Instructions for Form 990 Return of Organization Exempt From Income Tax, “Current officers, directors, and trustees” have no minimum compensation threshold in order for their names and salaries to be reported. Specifically, nonprofit employees classified as a “top management official” are treated as officers regardless of their titles. 

As stated by the IRS, an example of a top management official is an executive director, which makes an executive director an officer. This invalidates the claim that the CCA Foundation’s Executive Director was a key employee. Because nonprofit officers do not have a minimum compensation threshold for salary reporting, the CCA Foundation would likely be legally obligated to disclose the salary of their Executive Director.

This conclusion is further corroborated by the salary reporting practice of every other school Foundation in SDUHSD.

Source: Executive Director Salaries. CCA Foundation salaries from 2018-2020 are rough estimates as actual numbers were not reported, see spreadsheet for explanation. 

From 2018-2023, no Executive Director from TPHS, LCC, or SDA earned a yearly salary greater than $150,000. Despite that, every other Foundation in the district still reported their Executive Director salaries. 

The CCA Foundation also contradicted its own defense in 2013, 2014, and 2021: although the Executive Director made less than $150,000 in those years, their salary was still reported.

Overall, we don’t believe that classifying the Executive Director as a “key employee” is a valid defense for not reporting salaries from 2015 to 2020. In other words, faulty accounting gimmicks do not exempt a nonprofit from transparency.

“Other Program Expenses”

While providing a general explanation for “Other Program Expenses” is a good start, it’s simply not enough given the sheer size of the expense ($3.5M over 12 years). In 2023 alone, “Other Program Expenses” made up 37% of total expenses for that year. Donors have the right to know specifically where their money goes, and simply lumping together different large expenses together and providing a broad explanation for them does not fulfill that right.

We believe that the Foundation should release a detailed breakdown of “Other Program Expenses” for each year in the period 2012-2024, as it would provide full transparency as to where the money under that expense was going.

For example, instead of “Other Program Expenses: $100,000”, the CCA Foundation could divide the expense into “Cage and Nest: $30,000, Camp and Clinics: $25,000, Facility Improvements: $25,000, Other Program Expenses: $20,000”. This breakdown would give donors a much clearer picture of where a large portion of their money goes. 

In summary, we believe that one large “Other Program Expense”  is at least very poor accounting, as it completely fails to detail where a substantial amount of money went. Therefore, itemizing each significant expense under "Other Program Expense" is essential to providing a more transparent understanding of the nature of these expenses.

“75% to Discipline + 25% to General Funds = 100% Benefit to Students”

This section’s title is the CCA Foundation’s gross oversimplification of how their fee system works, which is also shown in the picture below.

Source: CCA Foundation Response

However, the reality is that a massive portion of the 75% kept and 25% general fund fee is virtually never seen by school organizations. We would also like to reiterate that the fees charged by the Foundations at Torrey Pines, LCC, and SDA all amount to between 5% and 10%, which makes the necessity of a 25% fee appear questionable.

Additionally, the CCA Foundation failed to even acknowledge the massive end-of-year fee charged to on-campus organizations. In the case of the robotics team, these arbitrary end-of-year fees were an exorbitant 28-34% of non-summer camp income per year, or roughly $85,000 over 6 years.

The CCA Foundation did not even mention this fee in their rebuttal, let alone explain how it was calculated. 

Source: STEM Fund Revenue & Management Expense

The Foundation has claimed, without evidence, that the entirety of the 25% fee towards general funds is returned to on-campus organizations in the form of shared/general expenses or towards day classes.

We challenge the CCA Foundation to provide any supporting financial documentation that supports this assertion.

CCAF’s Former President

A former president of the CCA Foundation’s board contacted us by email to express her support for our original report. She criticized the principal’s response to our criticisms, and also alleged that the former Executive Director ignored concerns and campaigned to remove members of the Foundation who disagreed with her. 

September 12th Board Meeting

The Foundation published their rebuttal two hours before the start of the SDUHSD school board meeting on September 12th. We believe that it was intended to sway public opinion on our report before we were able to publish a response.

Nevertheless, during the public comments at the board meeting, we received an incredible amount of support from parents who decided to leave a comment. So many people requested to leave a public comment at the board meeting that the school board shortened the time limit for public comments from 3 minutes to just 1 minute.

You can find the recording of the SDUHSD school board meeting at this youtube link. The public comments begin at 1:40:00. As the video shows, almost half of the commenters mentioned our report and we received an outpouring of praise and many calls for reforms at the Foundation. Only one commenter criticized our report, calling its motives “fascist”; we wholeheartedly disagree with this characterization.

We would like to thank the parents who have shown us so much support.

Unaddressed Claims

The Foundation’s report rebuttal failed to address the following concerns:

• The arbitrary expensive end-of-year charge on clubs and how that charge is calculated.

• Taking far more money from STEM clubs such as the robotics team than they invest into these clubs.

• Speech and Debate being told they were $40,000 in debt when they were not.

• The months-long wait required for individuals to be reimbursed by the Foundation

• The CCA Foundation charging far more fees than other Foundations within the district.

• The circumstances behind the end of the employment of the former Executive Director

However, in light of the Foundation’s rebuttal, we would like to clarify following:

• The 25% general fund fee is not seen only once as we previously stated: the fee is disclosed elsewhere such as in the calendar.

• The removal of the CCA Foundation’s former Executive Director was discreet, but not secret. Although most students and parents weren’t aware of this incident, there was one sentence mentioning it in the Foundation’s June newsletter.

Conclusion

In addition to providing no explanation for many of our main concerns, the responses that were provided by the CCA Foundation were largely incomplete and often misleading. We would like to reiterate our call for reforms at the Foundation, including lowering club fees to the levels at other schools in the district, officially appointing two student liaisons, and reporting their spending and compensation more transparently. 

The CCA Foundation has repeatedly stated that our report has damaged the reputation of their organization, which will result in a decrease in donations. However, we believe that if the Foundation wants to restore trust within the community, it should focus on solving the issues we highlighted rather than trying to discredit them.

We urge all everyone who believes the Foundation should operate in a more transparent and ethical manner to contact your school board member and urge that a vote on reforming the Foundation be included in the agenda for the next board meeting.

Note: we previously included a section regarding the Foundation's restricted funds. We have since deleted it as we found out the issue we mentioned was actually normal practice.