REQUIREMENTS AND METHODS FOR MAINTAINING ATTENDANCE AND ENROLLMENT

ADA Computation

Of course, classes subject to hourly attendance accounting are not required to be held only in exact 60-minute "clock hour" sessions. When a class is scheduled and held for more or less than an exact hour or multiple of an hour in each session, the resulting individual portions of hours of attendance credit (most easily accounted in minutes) are simply aggregated into whole hours of apportionment credit. Consistent with 5 CCR 404, if a student attends any part of, say, a 45-minute class session, s/he then may be credited with 45 minutes of attendance.

Instructional Time Requirements

"Minimum day"--fundamental concepts

California's compulsory attendance law requires that pupils "shall attend the public full-time day school or continuation school or classes for the full time designated as the length of the schoolday by the governing board of the school district" (§48200). The governing board's specific responsibility is set out in:

Day of attendance and weekly maximum credit

For apportionment purposes a day of attendance in continuation education is 180 minutes, but there is also an upper limit to the amount of apportionable attendance that a district can claim per pupil per week:

Within the weekly limit, however, a continuation pupil may be credited with more than one day of attendance in a given calendar day:

The flexibility afforded by these provisions allows a pupil's continuation schedule to include, for example, six hours each on Monday and Tuesday, three hours on Wednesday, and none on Thursday or Friday, with the resulting total of 15 hours in the week being apportionable as five three-hour "days" of continuation attendance.

Because 15 hours of attendance per week is the maximum amount of attendance with which a continuation pupil may be credited, it is not permissible for a pupil to "bank" credit for surplus hours of attendance and carry it forward beyond the week in which it was generated. If a pupil generates less than the maximum 15 hours of credit permissible within a full week, however, it then becomes permissible to credit a corresponding number of surplus hours generated in a succeeding week, so that on average the pupil will have generated "15 hours per week" since the pupil's first day of enrollment in the term. In other words, it is not permissible for a continuation pupil to "get ahead" in attendance, but it is permissible for the pupil to "catch up" to the permitted average. (Note that the monthly reports should clearly link preceding "short" weeks to weeks in which more than 15 hours are correspondingly credited.)

Passing time in departmentalized settings

CDE has for many years advised school districts that actual passing time between separate class sessions in the same departmentalized program, not to exceed 10 minutes in each instance, may be claimed as "instructional time" for apportionment credit. CDE has further advised, however, that passing time is not claimable between sessions in different programs. Hence, passing from a regular high school class to an ROP class--even if both are on the same campus--is not claimable.

Verification of apportionment-excused absences

The CCR specifies who may verify absences because of illness or quarantine, and the ways they may do so:

(1) A school or public health nurse.

Note that parent volunteers and student assistants are not among those who may verify.

In practice, school officials usually rely on one or the other of two main means of verifying illness absences: notes from parents/guardians, or telephone conversations they have logged after discussing the reasons for pupils' absences with (usually) the pupils' parents/guardians. In certain circumstances, subject to local policies, it may be necessary to verify on the basis of information gained through conversations with siblings or others judged to be reliable. In such instances CDE advises placing a specific explanatory notation in the attendance records audit trail.

While school officials may reasonably base verification on notes and telephone conversations which they have no reason to disbelieve, they may not of course accept an excuse if they have personal knowledge that provides a basis for a reasonable certainty that the excuse is false--and when in significant doubt, they should seek further confirmation.

By usual audit standards, adequate phone log entries and notes from home have common essential elements. The elements of a phone log entry are:

• the absent pupil's name

• the name of the person reached, and his/her relationship to the pupil

• the name of the verifying school employee
• the date of the call
• the date of the absence to which the call refers
• the reason for the absence.

The elements of an absence note are:

Pupils 18 and older may legally provide the basis for verification of their own absences (as may "emancipated minors"--see Civil Code §60 and following).

Notes and phone logs are Class 3 "Records Basic to Audit" (see Chapter V) to be retained for three years:

A note that is the basis for verification of an absence is a "source document," as auditors use the term, and must itself be retained in the record. A logged summary of its contents is not an acceptable substitute.

State law allows certain types of absences to be treated as if the pupil had actually attended the missed day. The law also allows other types of absences to be excused but not to be the basis for apportionment claims. The common term "excused absence," then, may mean two different things--and while neither of them is a truancy, only in the instance of a properly verified "apportionment-excused absence" can a district claim apportionment credit for the absent pupil.

It is important to note that the law does not allow apportionment-excused absence for pupils in summer school, classes for adults, opportunity program assignments (as opposed to full-time opportunity class assignments), or regional occupational centers or programs (except for pupils concurrently enrolled in both a regular program and a regional occupational center or program).

Absences allowable as apportionment attendance

The Education Code does not define "illness," but CDE suggests as a reasonable definition: `a temporary or intermittent affliction that makes it unwise or impossible for a pupil to attend school.' A pupil whose condition prevents his/her benefitting from instruction should of course not attend school, but the determining factor may also be the contagiousness of a pupil who otherwise "feels fine." (Formal public health quarantines have been all but unknown since antibiotics came into widespread use following World War II.)

The Education Code specifically provides for excusing pupils in grades 7-12 when they leave school to obtain confidential medical services:

For cases of prolonged illness or injury preventing attendance for an extended time, there are further provisions:

Excused absence credit is no longer applicable once an ill pupil begins receiving instruction in a hospital or in his/her home (see "Home/Hospital Instruction" in Chapter IV).

"Immediate Family," as set out in §45194 and applicable to excused absences for attending funerals, consists of the pupil's mother, father, grandmother, grandfather, grandchild, spouse, son, son-in-law, daughter, daughter-in-law, brother, sister, or other relative living in the pupil's immediate household.

A pupil excluded from school for lack of required immunizations may be claimed for apportionment attendance credit for up to five days, only, even if his exclusion lasts longer:

Under certain circumstances, pupils absent from regular school while engaged in school-sponsored field trips may also be claimed for apportionment attendance credit:

Excused absences

Verified absences in continuation education are creditable for apportionments as set out in §46010, but there are necessary limitations on the way credit may be claimed. Because of the calculational flexibility of the continuation week and day, the amount of apportionment creditable for an absence is not fixed, depending instead on the pupil's scheduled attendance for that day. In the case of the pupil scheduled to attend six hours each Monday and Tuesday, Wednesday three hours, and none on Thursday and Friday, an excused absence on Monday could be credited as two "days" of attendance, whereas an absence on Wednesday would be credited for only one "day."

In the case of a pupil who has been `overscheduled'--for example, who is scheduled for six hours a day on every day of the week--one day's absence may not be credited for more than the proportional three hours that the day's attendance would have contributed toward his/her 15-hour-per-week total.

When attendance in adult education classes and/or regional occupational centers or programs is used to satisfy compulsory continuation attendance requirements (§48410(d) and (f)--see following), excused absence credit is not allowed by statute. Section 46010 specifically disallows apportionment-excused absences in ROC/P's (except for pupils who are also enrolled in regular high school) and in adult education.

Recording and reporting attendance

Continuation education attendance must be reported by clock hour:

(See comments on hourly attendance accounting and reporting in Chapters III and V.)

As in regular departmentalized settings, actual passing time (not to exceed 10 minutes) between classes within a continuation program has been deemed to be instructional time (see "Instructional Time Requirements," in Chapter III).

Compulsory attendance implications

As noted in the Compulsory Attendance section, 16- and 17-year-old pupils must attend compulsory continuation education classes unless they are exempted (the majority of pupils being in fact exempt through attendance upon regular high school classes):

This minimum four hours of continuation education per week applies only to pupils who can satisfactorily prove they are regularly employed; otherwise the requirement is 15 hours per week:

Length of year

To qualify for basic revenue limit apportionments, a district must maintain its schools (other than those with year-round schedules) for at least 175 days each year:

Year-round schools may be in operation for as few as 163 days per year:

The 1983 Educational Reform Act established `longer year' financial incentives for districts that maintain school for at least 180 days (or the equivalent, for year-round schools only):

Staff development days as instructional time

For the purposes of total yearly minutes calculations for incentive funding, there are certain circumstances under which schools may claim credit for instructional minutes when students are not actually present. On a properly established "teacher inservice" or "staff development" day, when pupils attend for a minimum day or not at all, a school may claim apportionment and incentive funding credit for a full regular day. No more than eight such days may be claimed in any fiscal year. (The requirements applying to a local board's establishment of apportionable staff development days lie outside the scope of this manual.)

CDE has advised districts that as "provision of time during the regular school year," the staff development day(s) must be scheduled on one of the calendar days identified as a normal day of that regular school year in the official school calendar adopted by the local board--not on a Saturday or Sunday (on which non-truants may not be required to attend), or school holiday. CDE understands the law to provide that, for the purposes of instructional time computation, staff development days are separate one-day events and may not be divided into partial day equivalents: the maximum of eight days may not be turned into 16 half-days or any similar variant.

"During the regular school year" includes immediately preceding what would otherwise be the first normal day in the regular school year (or immediately following the last normal day), but a staff development day may not be isolated in vacation time. It is permissible to have two (or more) staff development days together back to back, if all the other qualifications are met.

If a staff development day is held in conjunction with a minimum day of student attendance, then the apportionable attendance of the minimum day is used. If students are not present for any part of the staff development day, then the total apportionable attendance on the last regular school day before or on the next regular school day after the staff development day is used to calculate apportionment attendance credit.

Truancy

Truancy from compulsory continuation attendance shares characteristics with truancy under the age 6-16 compulsory attendance law, with the parent/guardian having responsibility for ensuring the pupil's continuation attendance: