CACCRAO New Directors Training Update and Current Activities in Student Attendance Accounting and Reporting Presented by: Natalie Wagner, CCC Chancellor’s Office

Update on Student Attendance Accounting and Reporting 11/8/2018 Update on Student Attendance Accounting and Reporting AGENDA Fundamentals of Student Attendance Accounting and Reporting CCFS-320 Apportionment Attendance Report Reminders Annual Financial and Compliance Audit Recently Passed Legislation, Updates, and Current Issues Questions/comments

The Fundamentals What is FTES? How is FTES computed? 11/8/2018 The Fundamentals What is FTES? How is FTES computed? Where is FTES reported? CCFS-320 Online Reporting System When is FTES reported? Reporting periods What does the Chancellor’s Office do with the information reported? Where’s the supporting documentation? What could affect apportionment eligibility?

1. What is FTES? FTES is not a headcount 11/8/2018 1. What is FTES? California community college apportionment is primarily driven by the Full-Time Equivalent Student (FTES) workload measure. FTES is not a headcount Equivalent to 525 hours of student instruction Derived from one full-time student enrolled in 15 units per semester, which would normally equate to 15 Class hours per week 15 Class hours per week x traditional 35-week academic year = 525 1 FTES can be generated by 1 student or multiple part-time students Districts are required to report all resident and nonresident FTES, regardless of whether funding is available for some of those FTES Only resident FTES can be claimed for state apportionment

11/8/2018 2. How is FTES Computed? FTES is computed under one of the four available attendance accounting procedures ( T5 §58003.1). Weekly Census (T5 §§ 58003.1(b); 58004) Daily Census (T5 §§ 58003.1(c); 58004) Actual Hours of Attendance (Positive Attendance) (T5 §§ 58003.1(d), (e), (g); 58006) Alternative Attendance Accounting Procedure (T5 §§ 58003.1(f); 58009) Credit Independent Study, Work Experience Education, and Certain Distance Education Courses Noncredit Independent Study / Noncredit Distance Education Courses Title 5 prescribes the FTES computation formulas for each procedure. The “divisor” for each procedure 525. The majority of FTES are generated in Weekly Census procedure courses (available only to Credit primary term length courses scheduled the same amount of hours each week of the term)

11/8/2018 3. Where is FTES reported? FTES data is reported to the State Chancellor’s Office via the Apportionment Attendance Report (aka CCFS-320) Required by California Code of Regulations (CCR), title 5, section 58003.4 Prepared in accordance with deadlines and instructions prescribed by the Chancellor’s Office (T5 § 58003.4(d)) Districts utilize an online reporting system to submit their CCFS-320 Reports: https://misweb.cccco.edu/CCCFS320/Login.aspx

11/8/2018 4. When is FTES reported? Timely submissions and corrections of attendance accounting reports is critical (T5 §58003.4) First Period – July 1 thru December 31 (data is annualized) Due to Chancellor's Office by January 15 Second Period – July 1 thru April 15 (data is annualized) Due to Chancellor's Office by April 20 Annual Report – July 1 thru June 30 Due to Chancellor's Office by July 15 Recal Report – Revisions to Annual Report Due to Chancellor's Office by November 1 Timely submission of the CCFS-320 is very important!

5. What does the Chancellor’s do with the information reported? 11/8/2018 5. What does the Chancellor’s do with the information reported? Each reporting period corresponds to an apportionment allocation CCFS-320 FTES data is forwarded to the Chancellor’s Office Apportionment Section at each reporting period The Chancellor's Office calculates State General Apportionment allocations Allocations are based primarily on the number of FTES that districts report on the CCFS-320

6. Where’s the supporting documentation? 11/8/2018 6. Where’s the supporting documentation? Per T5 §58030, districts are required to adopt procedures and internal controls that will document all: Course enrollment Attendance Disenrollment This information is necessary for the creation of appropriate support documentation (records) that will enable an independent determination of the accuracy of FTES submitted by the district to the Chancellor’s Office as the basis of its claim for state support. 9

6. Where’s the supporting documentation? (Cont.) 11/8/2018 6. Where’s the supporting documentation? (Cont.) Among other things, the required T5 § 58030 procedures to document attendance and FTES should speak to the retention and destruction of support records. T5 § 59020 et seq. Support records relating to attendance and FTES are considered “Records Basic to an Audit” (RBA) under the “Class3– Disposable” classification, which means that they cannot be destroyed until after the third (3rd) July 1 succeeding the completion of the Annual Audit required by EC § 84040. T5 § 59025; 59026(b) Example: 2017-18 RBA records cannot be destroyed until after July 1, 2021 2017-18 – Annual Audit for this FY to be completed 12/31/18 T5 59106 July 1, 2019 July 1, 2020 July 1, 2021 – RBA records may be destroyed after this date Note: Extended record retention rules apply when support records relate to a Chancellor’s Office review/investigation or where there is deliberate district misrepresentation. T5 § 59118 10

7. What could affect apportionment eligibility? 11/8/2018 7. What could affect apportionment eligibility? Conditions Affecting Apportionment (T5§ 58050) Only FTES that meets statutory and regulatory apportionment conditions may be claimed for state apportionment. Some of these conditions include: Open course requirements Enrollment limits Immediate supervision and control by an appropriately qualified faculty member Course repetition, withdrawal, and overall apportionment enrollment limits Instructional service agreements (ISAs) Full-funding provisions Residency status Appropriate course and program approval Distance education In-service training courses for police, fire, corrections, etc. Clearing of census rosters 11

CCFS-320 Apportionment Attendance Report Reminders 11/8/2018 CCFS-320 Apportionment Attendance Report Reminders 12

CCFS-320 Apportionment Attendance Report Reminders 11/8/2018 CCFS-320 Apportionment Attendance Report Reminders Special Admit P.E. FTES Limits Districts are prohibited from claiming state apportionment funding for Special Admit students (part-time and full-time) enrolled in physical education (P.E.) courses in excess of 5% of the district’s total reported FTES of Special Admit students. (EC § 76002(a)(4)) Example: District generates 100 Special admit FTES, may only claim 5 (5%) in PE. Prior to certifying report, districts should verify adherence with this statutory prohibition Districts also need to monitor special admit enrollment in PE courses to ensure that no more than 10% (of total enrollment in a PE course section) is claimed for apportionment. Example: 30 Students in a PE course section, may only claim 3 (10%) special admit students 13

CCFS-320 Apportionment Attendance Report Reminders 11/8/2018 CCFS-320 Apportionment Attendance Report Reminders Contact Hour (CH) Computations Should be based on actual Contact Hours and the formula applicable to the particular course section, not Contact Hours as stated or targeted in the college catalog or course outline of record The Annual Contracted District Audit verifies compliance with this requirement 14

CCFS-320 Apportionment Attendance Report Reminders 11/8/2018 CCFS-320 Apportionment Attendance Report Reminders “Summer Shift” - Census Procedure Course Reporting FTES for Primary Term Census Procedure Courses are reported in the period in which the census procedure is completed, even if the course is not completed by the deadline for reporting FTES for Summer intersession Daily Census procedure courses that overlap fiscal years are to be reported in the fiscal year in which the census occurs, OR when the course ends (includes courses on Alternative Attendance Accounting Procedure-Daily) (T5 § 58010(a)) 15

Annual Financial and Compliance Audit 11/8/2018 Annual Financial and Compliance Audit All public local education agencies, including community college districts, are required to have an annual audit conducted by a CPA firm (EC § 84040.5) The Contracted District Audit Manual (CDAM) prescribes the requirements and procedures for the annual audit New CDAM issued for every FY Annual Audit Individual tests are periodically rotated out and replaced with other ones Section 400 of CDAM prescribes the various State Compliance Tests (18 tests in 2017-18) Of the 18 State tests, 7 directly relate to verifying FTES eligibility for State general apportionment. Findings in these areas could result in an apportionment adjustment. 16

Annual Financial and Compliance Audit (Cont.) 11/8/2018 Annual Financial and Compliance Audit (Cont.) 7 State tests that directly relate to FTES eligibility Instructional Services Agreement’s – ISA’s (423) General Apportionment Funding System (424) Residency (425) Students Actively Enrolled (426) Dual Enrollment (427) Open Enrollment (435) To Be Arranged Hours – TBA (479) 17

Selected 2016-17 State Compliance Audit Findings (Cont.) 11/8/2018 Selected 2016-17 State Compliance Audit Findings (Cont.) Incorrect application of Attendance Accounting Procedures (T5 §§ 58000 et seq.) Common deficiencies: Example 1: Credit course does not meet the same amount of hours per week, so Weekly Census procedure incorrectly applied Example 2: Support records for positive attendance hours generated did not agree with hours claimed Example 3: Claiming students that were required to be removed from census roster Example 4: Apportionment claimed for cancelled “census-based” classes. For cancelled courses, the following rules apply: Positive Attendance courses – Apportionment can be claimed for actual student contact hours generated by the student up to their drop. Census-based classes (weekly or daily) cancelled before or after census, apportionment cannot be claimed for the entire course because it ceases to be regularly scheduled. 18

Updates and Current Issues 11/8/2018 Updates and Current Issues 19

Recently Approved Legislation AB 1809 Budget Trailer Bill- Apprenticeship Changes Beginning in 2018-19, districts may report hours generated by apprentices on the CCFS- 320 if not reported on the CCFS-321 (must use positive attendance method to calculate FTES) Course must be taught by a community college faculty member to report attendance on the CCFS-320 Enrollment may be limited to apprentices if that course or course section is required for those students as a part of a registered apprenticeship program. If the course is part of an apprenticeship program in the building and construction trades, the sponsor must approve a decision to report attendance on the CCFS-320 rather than on the CCFS-321.

Recently Approved Legislation AB 1809 Budget Trailer Bill- CCAP Dual Enrollment Changes CCCs may now enter into a CCAP agreement with  the governing body of a charter school Districts may limit enrollment (closed courses) solely to eligible HS students if the course is offered at a HS campus either in person or using an online platform during the regular school day Component added to the CCAP annual reporting requirements: report must include the total number of FTES served online generated by CCAP participants

Recently Approved Legislation 11/8/2018 Recently Approved Legislation Assembly Bill 637 (Medina, 2017) AB 637 (effective January 1, 2018) establishes cross enrollment in online education among California Community Colleges, adding section 68101, and Chapter 9.7 commencing with section 66770 to the Education Code. Authorizes a California Community College student who meets specified requirements to enroll in an online course provided by another CCC campus (referred to as a teaching college) through the OEI Consortium. Requires the Chancellor's Office to establish an online methodology that allows a student to access the online cross-enrollment option and simultaneously enroll in courses at his or her home college and courses provided entirely online by another teaching college 22

Recently Approved Legislation 11/8/2018 Recently Approved Legislation Assembly Bill 637 (Medina, 2017) Allows a “teaching” college to accept the residency determination of the “home” college under certain conditions including: The student is cross-enrolling in a course available through the online course exchange The home college certifies the student’s residency classification made by the district The student is enrolling in a course available at the teaching college through the online course exchange The home college and the teaching college are both part of the Online Education Initiative Consortium 23

Recently Approved Legislation 11/8/2018 Recently Approved Legislation Assembly Bill 343 (McCarty, 2017) AB 343 (effective January 1, 2018) added section 68075.6 to the Education Code. This section grants an immediate Nonresident Tuition fee exemption to eligible Special Immigrant Visa (SIV) holders and refugee students (important to note that eligible T and U Visa holders are also eligible for this immediate exemption based on the provisions of Education Code section 68122, which ties their exemption status to that of refugees).   24

Recently Approved Legislation 11/8/2018 Recently Approved Legislation Assembly Bill 343 (McCarty, 2017) Eligibility for this nonresident tuition fee exemption includes the requirement that  “upon entering the United States, [the Student] settled in California”.   This exemption for is only available for the minimum time it would take for the student to establish residency (one year and one day). Therefore a student who arrives in California on January 1, 2017 and enrolls in the Fall term, should be granted resident classification under this exception only until January 1, 2018. For minors, the exception is for one year from the date the student becomes 18 years of age (to age 19). 25

AB 540 Updates AB 540 Nonresident Tuition Exemption (effective January 1, 2002) Original Eligibility Criteria: Attended HS in California for three or more years AND graduated from a California HS (or attained the equivalent). Effective January 1, 2013, AB 1899 (EC § 68122). expanded eligibility to include nonimmigrant alien students holding “T” or “U” Visas. Effective January 1, 2015, AB 2000 (EC § 68130.5) expanded eligibility to include students who: Demonstrate attainment of credits earned in California from a California HS equivalent to three or more years of full-time HS coursework AND a total of three or more years of attendance in California elementary/secondary schools or a combination of those schools AND graduated from a California HS (or attained the equivalent).

AB 540 Updates Recently Approved Legislation: SB 68 (Lara, 2017) 11/8/2018 AB 540 Updates Recently Approved Legislation: SB 68 (Lara, 2017) SB 68, effective January 1, 2018, amended Education Code section 68130.5 and significantly expanded eligibility criteria for AB 540. Two main changes: Attendance Requirement: SB 68 amended the attendance requirement to allow attendance (or credits earned) at: California High Schools, California Adult Schools, California Community Colleges (limit: 2 years in CCC credit courses), or a combination of these, to count toward the three year requirement. Completion of a course of study: Under SB 68 a student may satisfy the completion requirement with graduation from a California high school or the equivalent, OR attainment of an AA degree from a CCC OR fulfilment of the minimum requirements to transfer to a UC or CSU.

Current AB 540 Exemption Eligibility Criteria 11/8/2018 Current AB 540 Exemption Eligibility Criteria Requirement 1: Attendance at California schools Two Paths: Total attendance (or attainment of credits earned) in California equivalent to three or more years of full-time attendance at California high schools, California high schools established by the State Board of Education, California adult schools (established by a county office of education, a unified school district or high school district, or the Department of Corrections and Rehabilitation), campuses of the California Community Colleges, or a combination of these; or Three or more years of full-time California high school coursework, and a total of three or more years of attendance in California elementary schools, California secondary schools, or a combination of California elementary and secondary schools.

Current AB 540 Exemption Eligibility Criteria 11/8/2018 Current AB 540 Exemption Eligibility Criteria Requirement 2: Completion of a course of study This requirement may be met in any of the following ways: Graduation from a California high school or equivalent. Attainment of an associate degree from a California community college. Fulfillment of the minimum transfer requirements established for the University of California or the California State University for students transferring from a California community college. (Ed. Code, § 68130.5, subd. (a)(2).)

Current AB 540 Exemption Eligibility Criteria 11/8/2018 Current AB 540 Exemption Eligibility Criteria Requirement 3: Registration. Requires registration as an entering student at, or current enrollment at, an accredited institution of higher education in California. Requirement 4: Affidavit of student without lawful immigration status. Students without lawful immigration status must file an affidavit with their college or university stating that the student has either filed an application to legalize his or her immigration status, or will file an application as soon as he or she is eligible to do so. (Note: All students seeking the AB 540 exemption must complete the affidavit.)

AB 540 Attendance Requirement Full-time Attendance Equivalents   1-Year Equivalent 3-Year Equivalent High School 55 credits 165 credits Adult School 420 class hours 1260 class hours Community College (Credit) 24 credit units May only use up to two years (48 credit units) Community College (noncredit) 420 class hours

Regulatory Changes (Approved) Nonresident Students in Noncredit Courses In May 2018, the Board of Governors approved a change to T5 section 58003.3. The change eliminates the requirement that students be lawfully admitted in order for districts to claim apportionment for nonresident students in noncredit courses. § 58003.3. ALIEN STUDENTS. APPORTIONMENT FOR NONCREDIT COURSES Notwithstanding section 68062 of the Education Code, for the purposes of crediting community college attendance for apportionments from the State School Fund, a community college district may claim the attendance of students living in California who have been lawfully admitted to the United States in accordance with all applicable laws of the United States and enrolled in noncredit courses in the district.

Regulatory Changes (Proposed) Supervised Tutoring Self- Referral Current regulations require students to be referred for “Supervised Tutoring” by a faculty or a counselor based on an identified learning need. The faculty or counselor referral process is cumbersome and problematic for students because of the reluctance of students to request the referral. This proposed change will enable students to self-refer themselves to “Supervised Tutoring.” § 58170. APPORTIONMENT FOR TUTORING (e) Students enroll in the Supervised Tutoring course, through registration procedures established pursuant to section 58108, after referral by the student, a counselor, or an instructor on the basis of an identified learning need.

Pending Legislation AB 3101 (Carillo, 2018) Exempts students enrolled in only noncredit courses from the residency classification requirements. Adds Section 68086 to the Education Code, to read: 68086. (a) A student seeking to enroll exclusively in career development and college preparation courses, and other courses for which no credit is given, at a community college shall not be subject to the residency classification requirements of Article 3 (commencing with Section 68040). (b) Nothing in subdivision (a) shall prohibit the Chancellor of the California Community Colleges from collecting residency data, for a student described in subdivision (a), that is voluntarily submitted by the student after he or she enrolls at a community college.

11/8/2018 Questions/Comments

Natalie Wagner (916) 327-1554 nwagner@cccco.edu Chancellor’s Office 11/8/2018 Contact Information Natalie Wagner (916) 327-1554 nwagner@cccco.edu Chancellor’s Office 36