Independent Study Attendance Accounting and Audit Issues for Charter Schools California Consortium for Independent Study November 7, 2016 Wendi McCaskill,

Independent Study Attendance Accounting and Audit Issues for Charter Schools California Consortium for Independent Study November 7, 2016 Wendi McCaskill, California Department of Education Arlene Matsuura, California Department of Education

School Fiscal Services Division
AGENDA Legislative Changes Independent Study & Attendance Accounting Overview Pupil Eligibility Written Agreements and Requirements Work Assignments and Records Attendance Credit Attendance Reporting Apportionment Requirements Audits Audit Findings Appeals Course Based Independent Study (CBIS) Highlights Issues School Fiscal Services Division

Legislative Changes Clarification that all independent study related documentation may be maintained electronically and that hard copies are not required if copies are available electronically EC Section 51747(c)(8) (A) Each written agreement shall be signed, before the commencement of independent study, by the pupil, the pupil’s parent, legal guardian, or caregiver, if the pupil is less than 18 years of age, the certificated employee who has been designated as having responsibility for the general supervision of independent study, and all persons who have direct responsibility for providing assistance to the pupil. For purposes of this paragraph “caregiver” means a person who has met the requirements of Part 1.5 (commencing with Section 6550) of Division 11 of the Family Code. School Fiscal Services Division

Legislative Changes EC Section 51747(c)(8) (B) A signed Signed written agreement agreements, supplemental agreements, assignment records, work samples, and attendance records assessing time value of work or evidence that an instructional activity occurred may be maintained on file electronically. as an electronic file. (C) For purposes of this section, an electronic file includes a computer or electronic stored image of an original document, including, but not limited to, portable document format (PDF), JPEG, or other digital image file type, that may be sent via fax machine, , or other electronic means. (D) Either an original document or an electronic file of the original document is allowable documentation for auditing purposes. School Fiscal Services Division

Legislative Changes Update Students participating in home-based private instruction or independent study without classroom-based instruction do not have to meet the immunization requirements (Health and Safety Code Sections , , , and ) Classroom-based instruction is not currently defined for the purposes of immunization requirements Even if students aren’t immunized, LEAs still need to submit records indicating that the students are not immunized For now, the sample of students selected to test by the auditor when performing immunization procedures will exclude Students in independent study Students with an individualized education program that includes special education and related services School Fiscal Services Division

Independent Study Attendance Accounting
School Fiscal Services Division

Overview Charter schools do not have a five day minimum requirement to participate in independent study in order to generate ADA Attendance credit based on time value of work product submitted and a daily engagement record Time value determined by a certificated employee of the school Work must be submitted by established due dates in order to generate ADA Time value must equate to a full day of school as determined by certificated teacher School Fiscal Services Division

Overview Independent study participation requires a master agreement to generate ADA Local education agencies must meet ADA to FTE certificated employee ratio requirements ADA that exceeds the ADA to FTE ratio threshold cannot be claimed for funding Independent study pupils cannot generate more than one day of attendance per pupil, per day School Fiscal Services Division

Overview Based on 2015-16 P-2 Reported ADA:
P2 Reported Average Daily Attendance (ADA) School Districts Charter Schools Independent Study ADA 30,606 138,466 Total ADA 5,351,896 545,017 Percentage of Independent Study ADA 0.57% 25.41% School Fiscal Services Division

Pupil Eligibility Pupils must meet residency requirements Pupils over 21 cannot generate independent study ADA Pupils who have not been continuously enrolled since their 18th birthday can only generate independent study ADA until they are 19 Pupils with an IEP must have independent study included in IEP in order to participate Students suspended or expelled are excluded from school, thus they are also excluded from independent study School Fiscal Services Division

Master Written Agreements
Authorization to substitute performance or study for presence in classroom Agreement duration up to one year Dated signatures required before commencement of independent study School Fiscal Services Division

Master Written Agreement Requirements
Manner, time, frequency and place for submitting a pupil’s assignments and for reporting progress Objectives and methods of study for pupil’s work Methods used to evaluate pupil’s work Specific resources including materials and personnel made available to pupil Statement of policies regarding maximum length of time allowed between the assignment and the completion of assigned work Statement of policies regarding the number of missed assignments allowed prior to an evaluation School Fiscal Services Division

Duration of the agreement, including beginning and end dates not to exceed one year Statement of number of course credits or other measures of academic accomplishment to be earned upon completion. Statement that independent study is optional Statement that instruction may be provided only if pupil is offered a classroom alternative Signatures recorded prior to the commencement of independent study School Fiscal Services Division

Required signatures: Pupil Parent, guardian or caregiver, unless student is 18 or officially emancipated Certificated person responsible for supervising student’s independent study, i.e., the supervising teacher Any other persons who have direct responsibility for providing assistance to pupil School Fiscal Services Division

Work Assignments and Records
Student Assignments Representative samples of student’s regular work products need to be maintained, and can be maintained electronically Sample work products need to correspond to assignments CDE recommends at least one completed work product for each subject every two weeks Teacher dated initials are not required on work products Student assignments and work records must be kept for 3 years School Fiscal Services Division

Work Assignments and Records
Teacher Record Basis of apportionment and academic credit for ADA Teacher maintains record for each student under his/her supervision Record includes each assignment due date and meeting with student Record of time value and academic credit Must be kept for 3 years School Fiscal Services Division

Attendance Credit Teacher Record Time value for submitted work must be equivalent to a full day of work to generate attendance credit as personally judged by a certificated employee of the school. There needs to be a record of educational activities occurring on each school day that attendance is claimed. Attendance is in whole days Cannot exceed one day of apportionment credit per day of instruction (combination of classroom and independent study) School Fiscal Services Division

Attendance Credit Attendance Credit versus Academic Credit Effort devoted to assigned work used for attendance credit Effort is individually determined Quality of achievement used for academic credit Work sometimes needs to be reassigned for academic credit Teacher should include an explanatory note when the same assignment is reported for attendance credit more than once Ideally the supervising teacher is aware before the assignment is due that the student is not performing satisfactorily and can provide support School Fiscal Services Division

Attendance Reporting Attendance is based on time value and a daily engagement record and reported in increments of days Independent study ratio of ADA to FTEs must be evaluated against the ratio of the largest unified school district in the county or a ratio of 25 to 1. If the independent study ratio exceeds the comparative ratio the difference is considered excess ADA Excess ADA does not generate funding and is reported on a separate line in attendance reporting screen Eligible independent study ADA for charter schools are reported with regular ADA through the Attendance Charter School District entry screen in the Principal Apportionment Data Collection Software (PADC) School Fiscal Services Division

Apportionment Requirements
Pupils must be residents of the county or immediately adjacent county to the county in which apportionment claim is reported Pupil’s residency cannot be established based upon parent’s place of employment Pupils must be enrolled and identified by grade level, program placement, and school of enrollment There must be equity in resources between participants in independent study and pupils who attend regular classes School Fiscal Services Division

Time value of work products must be determined by a certificated teacher Board adopted written policies which include: Maximum length of time by grade level and type of program between date assignment is made and due date of assignment. Number of allowed missed assignments before an evaluation is conducted. Requirement that current written agreement meeting specific statutory requirements be maintained on file School Fiscal Services Division

If more than 20% of the school’s total ADA is non-classroom based, then the school must also have a funding determination. Information on funding determinations can be found at: School Fiscal Services Division

Audits School Fiscal Services Division

Independent Study Audit Findings
Number of independent study findings over last four years: Fiscal Year Districts and County Offices Charter Schools Appealed to EAAP* ** 31 7 2 25 6 4 24 5 3 10 *EAAP – Education Audit Appeals Panel School Fiscal Services Division

independent study deficiencies: (total 75 ADA questioned) 17 noncompliant agreements (missing signatures, contract elements) 13 ADA claimed before signatures obtained 5 attendance errors or lack of attendance documentation 5 missing work samples 3 lacked educational activity documentation (charter) 2 inconsistent or missing time value documentation 1 independent study ADA exceeded continuation ed 10% cap 1 did not meet ratio School Fiscal Services Division

independent study deficiencies: (total 134 ADA questioned) 18 noncompliant agreements (missing signatures, contract elements) 12 ADA claimed before signatures obtained 3 missing work samples 1 attendance errors or lack of attendance documentation 1 did not meet ratio 1 things of value provided to IS students 1 no certificated teacher (online school supervised by attendance secretary) 1 lacked educational activity documentation (charter) 1 no agreement School Fiscal Services Division

Independent Study Audit Appeals
Education Audit Appeals Panel (EAAP) accepts informal and/or formal appeals Voluntary, informal summary review per EC (d) Decision made by EAAP Executive Officer Basis for granting appeal – clearly constitutes substantial compliance School Fiscal Services Division

Formal appeals per EC 41344(d) Appeal heard by an Administrative Law Judge (ALJ) Usually involves legal counsel, but an LEA can represent itself Parties can reach a settlement but EAAP must accept the settlement Basis for granting appeal – substantial compliance with all legal requirements, finding based on errors of fact or interpretation of law School Fiscal Services Division

Summary of IS appeals filed Certain students had two teachers (general education and math), but only one supervising teacher signed the agreements. (14 ADA) Granted informal summary review relief – reduced to 0. Agreements were missing necessary information or had incorrect course information (used template from another LEA), attendance records did not agree with contemporaneous logs or contemporaneous logs missing (10 ADA) Pending informal summary review School Fiscal Services Division

Summary of IS appeals filed School provided IS students things of value that it didn’t provide to classroom students (22 ADA) Was not granted informal summary review relief Did not file formal appeal – repaid full amount of finding Agreements were missing required elements, one agreement signed after student enrolled, six agreements missing a required signature, no evidence that teacher evaluated work (28 ADA) Pending formal appeal School Fiscal Services Division

Summary of IS appeals filed Master agreement did not have maximum length of time between assignments, but school followed policy (1 ADA) Granted informal summary review – reduced to 0 Missing semester agreements and work samples (13 ADA) Was not granted informal summary review relief Did not file formal appeal – repaid funds School Fiscal Services Division

Summary of IS appeals filed Agreements signed after school year (4 ADA) Reached settlement on formal appeal to repay full amount over eight years – no interest IS ratio exceeded ratio of all other programs (10 ADA) Granted informal summary review – reduced by half District hired teachers for new school, but enrollment at school did not occur so “all other programs” ratio was low School Fiscal Services Division

Summary of IS appeals filed Charter school did not have daily engagement records (8.5 ADA) Was not granted informal summary review relief Did not file formal appeal – repaid funds Synchronous online school took classroom attendance rather than use independent study agreements (1208 ADA over 7 years) Settled 7 years of findings (over $8.1 million) for $818K payable over 8 years and school closed School Fiscal Services Division

Course Based Independent Study (CBIS)
School Fiscal Services Division

Highlights of Course Based Independent Study
Refer to Education Code Section and for complete set of requirements A new alternative method for operating and reporting independent study beginning with the school year In general, replaces making time valued assignments with enrolling in an authorized “course” Attendance earned if all requirements are met and the pupil is making satisfactory progress Reported separately from traditional independent study ADA Requires separate independent study ratio calculation Governing board/body must adopt independent study policies that comply with CBIS laws School Fiscal Services Division

Governing board/body must annually certify CBIS courses to be the same rigor and quality as equivalent classroom-based courses and shall be aligned to all relevant content standards. Certification to include Duration of course Number of equivalent daily instructional minutes Number of equivalent total instructional minutes Number of course credits for each course Voluntary signed learning agreement completed before commencing instruction CBIS courses are taught by certificated teachers with appropriate subject matter credential, who meet the HQT requirements, and who are employed by the LEA School Fiscal Services Division

Pupils must meet applicable residency, enrollment, and age requirements Certificated employee and pupil must communicate in person, by telephone or other live visual or audio connection no less than twice per calendar month to assess satisfactory progress. Pupils enrolled in CBIS courses must be offered the minimum annual total equivalent instructional minutes (can be combined with other modes of instruction) Pupils enrolled in CBIS courses, along with other courses, must met applicable annual instructional minutes Pupils cannot be prohibited from participating in these courses solely on the basis that the pupil does not have the materials, equipment, or internet access Satisfactory educational progress must be made to stay enrolled in CBIS School Fiscal Services Division

Satisfactory educational progress includes: Applicable statewide accountability measures Completion of assignments, examinations or other indicators that evidence the pupil is working on assignments, learning required concepts, and making progress toward successful completion of course Determined by certificated employee providing instruction. If satisfactory progress is not being made Notification to pupil and parents Conduct an evaluation to determine if alternative placement should be made Maintain a written record of the unsatisfactory progress evaluation which is considered a mandatory interim record and must be maintained for 3 years Maintain written or computer-based evidence of satisfactory progress for each pupil and each course. Evidence shall include: A grade book or summary document that lists all assignments, examinations and associated grades. School Fiscal Services Division

No more than 1 ADA can be earned per pupil First 10 percent of total LEA ADA is at full rate All CBIS ADA in excess of the first 10 percent is reduced by the statewide average absence for elementary (K-8) or high school (9-12) as calculated by the CDE for the prior fiscal year. The statewide average absence rate for is 4.5% for elementary (grades K-8) and 6.56% for high (grades 9-12). The average absence rate for is posted to CDE’s web site at: School Fiscal Services Division

Course Based Independent Study Issues
Examinations are required to be proctored, but “examination” and “proctor” are not further defined Is a proctor a certificated teacher? Is an examination any test taken to assess pupil’s learning? When combining classroom and CBIS instruction, ADA is reported as CBIS ADA which may skew the independent study ratio calculation If a certificated teacher provides both classroom and CBIS instruction, the teacher’s FTE will have to be allocated If an LEA has an MOU with another LEA, it would presumably be to provide a pupil with a course the first LEA doesn’t offer. Advise caution that this doesn’t conflict with the requirement that certain courses cannot be offered exclusively through independent study. School Fiscal Services Division

References Charter school independent study- Education Code sections and California Code of Regulations, Title 5 Sections 11960, through Independent study program requirements and restrictions on apportionment—Education Code sections through Course-based independent study program and requirements - Education Code sections and General independent study provisions, standards, and charter specific provisions; California Code of Regulations, Title 5 Sections through 11705 Guide for Annual Audits of K-12 Local Education Agencies and State Compliance Reporting can be found at: School Fiscal Services Division

Acronyms ADA = Average Daily Attendance FTE = Full Time Equivalent IEP = Individualized Education Program IS = Independent Study CBIS = Course Based Independent Study COE = County Office of Education PADC = Principal Apportionment Data Collection LEA = Local Education Agency School Fiscal Services Division

Thank you for participating!
Contact Information: Wendi McCaskill School Fiscal Services Division

Independent Study Attendance Accounting and Audit Issues for Charter Schools California Consortium for Independent Study November 7, 2016 Wendi McCaskill,

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