Attendance Accounting Webinar: Courses with Hours by Arrangement Course Repetition and Withdrawal

CCC Chancellor’s OfficeCCC Chancellor’s OfficeNovember 10, 2011November 10, 2011

John Mullen, Senior ConsultantJohn Mullen, Senior ConsultantStrata Information GroupStrata Information Group

Elias Regalado, Specialist, AllocationsElias Regalado, Specialist, AllocationsChancellor’s Office, California Community CollegesChancellor’s Office, California Community Colleges

Before we begin . . .

What problems are districts and their contract auditors finding as they audit 2009-10 and 2010-11 CCFS-320 reports?

• Various problems with TBA hours scheduling

• Course scheduling inconsistent with hours in the official course outline of record

• Incorrect attendance accounting method

• No supporting documentation that census rosters are cleared of inactive enrollment

Before we begin . . .

What problems are districts and their contract auditors finding as they audit 2009-10 and 2010-11 CCFS-320 reports?

• Apprenticeship hours reported on CCFS-320

• Courses fully funded via Contract Education reported on CCFS-320

• Flexible Calendar implementation problems

• Course contact hours based on target catalog hours rather than schedule of classes

Before we begin . . .

What problems are districts and their contract auditors finding as they audit 2009-10 and 2010-11 CCFS-320 reports?

• Residency determination issues

• Local holidays that impact apportionment eligibility

• Instructional Service Agreement (ISA) issues that impact apportionment eligibility

Hours By Arrangement

We will discuss the requirements that must be met in order to claim apportionment for contact hours by arrangement as part of a Weekly Census or Daily Census credit course.

Hours by arrangement are frequently referred to as TBA (To Be Arranged) hours in class schedules and other publications.

Hours By Arrangement

This discussion does NOT involve credit or noncredit Positive Attendance classes since only the actual hours of student attendance are reported for these classes.

This discussion does NOT involve classes reported by the Alternative Attendance Accounting Method (formerly known as Independent Study/Work Experience).

Hours By Arrangement

Most courses with a distance education component must be reported by the Alternative Attendance Accounting Method and are therefore NOT involved in this discussion.

We may schedule a future webinar covering attendance accounting for distance education courses.

Hours By Arrangement

TBA Definition: To Be Arranged• Some courses with regularly scheduled hours of

instruction have TBA hours as part of the total contact hours for the course.

• Some courses might have all contact hours on a TBA basis.

• TBA hours can be scheduled on a fixed basis for each student or can remain variable, but special documentation is required for either option.

Basic Rules for HBA Courses

Instructor must meet minimum qualifications or equivalency.

Course outline must include specific instructional activities expected of all enrolled students during TBA hours.

Students must be informed of these activities and expectations for completion.

Basic Rules for HBA Courses

Instruction must be provided during TBA hours that is NOT supervision of an activity that should be done independently outside of class time.

Students must still be required to study independently outside of class time. For lecture courses, the expectation is two hours of study for each class hour.

Basic Rules for HBA Courses

A clear description of the course, including the number of TBA hours, must be published in the catalog and schedule of classes (in print and/or online).

Students must be informed of the designated location where instructional activities during TBA hours will occur .

Basic Rules for HBA Courses

Days, times, and number of TBA hours attended by each student must be recorded by sign in/sign out on paper or electronically and available for audit.

An instructor meeting minimum qualifications must be present during all TBA hours, even if assisted by an instructional aide.

Attendance Accounting & Reporting

The course outline of record must specify the number of required contact hours as a whole, including any TBA hours.

Contact hours claimed for apportionment must be consistent with the course outline of record.

Students must be informed of specific times at which TBA instruction will occur.

Attendance Accounting & Reporting

If a course reported for apportionment includes TBA hours, documentation is required to demonstrate that each student has completed the minimum TBA requirement.

Apportionment for TBA hours cannot be claimed for students who have recorded zero TBA hours of attendance as of the census date of the class.

Attendance Accounting & Reporting

For Weekly Census classes, TBA hours must be scheduled for the same number of hours each week. Student TBA schedules may be fixed or variable, but the required hours must be completed each week.

Attendance Accounting & Reporting

For Daily Census classes, TBA hours must be scheduled for the same number of hours on each scheduled day. Student TBA schedules may be fixed or variable, but the required hours must be completed each day the class meets.

TBA hours are therefore impractical for most Daily Census classes, and hence present a challenge for summer classes.

Attendance Accounting & Reporting

If TBA hours are not scheduled as outlined above, attendance for the entire course must be reported as Actual Hours of Attendance (Positive Attendance).

Links to Reference Documents To Be Arranged (TBA) Hours Compliance Advi

ce (Legal Advisory 08-02), October 1, 2008

To Be Arranged (TBA) Hours Follow-up Memorandum, January 26, 2009

Second To Be Arranged (TBA) Hours Follow-up Memorandum, June 10, 2009

Contracted District Audit Manual for 2010-11, Item No. 429

Questions and Answers

Course Repetition and Withdrawal

New regulations adopted by Board of Governors on July 11, 2011, became effective on October 12, 2011.

Colleges are expected to fully implement with appropriate policy changes and public notice in time for Summer 2012.

Next scheduled college catalog update should reflect the required policy changes.

Effect of Title 5 Changes New definition of enrollment for

apportionment purposes: An enrollment occurs only when a student receives an evaluative or nonevaluative symbol for the course. [§58161]

Apportionment claims are limited to a maximum of three semesters or five quarters in a credit course, including any combination of withdrawals and repetitions. [§58161(a)]

Effect of Title 5 Changes Apportionment for one additional

enrollment can be claimed for certain exceptions:• Significant lapse of time [§55043]

• Extenuating circumstances [§55045]

Effect of Title 5 Changes Per §58161(c), no apportionment limitation for:• Legally mandated training [§55041(b)]

• Disability-related accommodation in special classes [§56029]

• Variable Unit Open Entry/Open Exit courses to the extent permitted by §55044

• Cooperative work experience courses within overall unit limitation [§55253]

• Withdrawals resulting from extraordinary circumstances (e.g., fire, flood) [§55024 (a) (10)]

• Military withdrawals [§55024 (d) (1)]

Effect of Title 5 Changes New enrollment limits apply only to credit courses

NOT designated as “repeatable”.

Enrollment limits for “repeatable” courses continue as they were prior to the adoption of the new regulations. [§58161 (d); 55041 (c)]

District policy must limit W’s for the same course to a number not greater than three. [§55024 (a) (9)]

District may permit enrollment in credit courses beyond the stated limits, but such enrollments may not be claimed for apportionment. [§58161 (e)]

Course Repetition and Withdrawal All prior credit course repeats and

withdrawals in student’s record will count toward the new limit.

Students’ decisions to repeat or withdraw from courses will have more implications under the new policies.

Colleges should provide guidance to students so they can make informed enrollment and withdrawal choices.

Course Repetition and Withdrawal Colleges should begin now to train

counselors, advisors, and other faculty so they can explain changes to students as they consider plans to enroll in or withdraw from courses.

Programming changes will probably be required in college information systems to reflect the new apportionment limits.

Course Repetition and Withdrawal Districts will need to modify catalogs,

schedules of classes, websites, and other college information given to students to reflect the new apportionment limits.

Important Points Students may enroll in a variable unit open

entry/open exit credit course as many times as it takes to complete the course curriculum one time.

District policy may permit the student to repeat a variable unit open entry/open exit course to alleviate substandard work within the limits of Title 5, Section 55042.

Important Points Each time a student enrolls in a physical

education activity course offered on an open entry/open exit basis, regardless of the number of units for which the student enrolls, the enrollment counts as a repetition of the course.

Apportionment claims for repeatable courses are limited to a maximum of four semesters or six quarters even if a student receives a substandard grade or petitions for special circumstances repetition.

Links to Reference Documents Advisory Regarding Title 5 Repetition and

Withdrawal from Credit Courses (September 12, 2011)

Follow-up Advisory Regarding New Title 5 Apportionment Limits for Credit Course Enrollment, Repetition and Withdrawal (October 12, 2011)

Full Regulations as filed with the Secretary of State

Questions and Answers

Contact information:

John MullenStrata Information GroupPhone: 650.533.6850Email: mullen@sigcorp.com

Elias RegaladoFiscal Services, Chancellor’s OfficePhone: 916.445.1165Email: eregalad@cccco.edu