Attendance Compliance

Attendance Generation Policy

v0.1 — Draft policy document.

Last edited 62 days ago by Bobby Valentine

1. Purpose

This document specifies the comprehensive attendance generation policy for in-person instruction at Highlands Community Charter School, an adult K-12 public charter school (hereafter "School"). The purpose of this policy is to:

a) Ensure accurate daily recording and reporting of student attendance in compliance with all applicable laws, regulations, and audit requirements;

b) Establish clear procedures for generating, maintaining, and verifying attendance records;

c) Define roles and responsibilities for all staff involved in the attendance process;

d) Provide guidance on the calculation and reporting of Average Daily Attendance (ADA);

e) Ensure the School's attendance procedures align with the requirements set forth in Education Code section 47612 and title 5, California Code of Regulations, section 11960;

f) Establish internal controls to prevent errors and detect any discrepancies in attendance reporting;

g) Facilitate the successful completion of annual audits related to attendance.

1.1. Scope

a) This policy applies to all operators assigned to generate and manage classroom-based attendance at the School. This includes, but is not limited to, teachers, administrative staff, attendance clerks, and school leaders. This policy covers all aspects of attendance taking, record-keeping, and reporting for the purposes of compliance and funding.

b) While this policy primarily addresses attendance generation, it is closely linked to the School's attendance reporting policy. The attendance reporting policy can be found [here].

c) This policy shall be reviewed and updated annually to ensure ongoing compliance with changing laws, regulations, and best practices in attendance management.

2. Requirements

The School must record student attendance daily for the purposes of compulsory education and state funding. If the recorded attendance meets all specific statutory and regulatory requirements, the School may report those records to claim apportionment, known as average daily attendance (hereafter "ADA") (EDC

@§ 47612.5⁠

2.1. Legal and Regulatory Compliance

The School shall comply with all applicable laws and regulations regarding attendance for adult education and WIOA programs, including but not limited to:

a) Education Code section

@§ 47612⁠

;

b) Title 5, California Code of Regulations,

@§ 11960⁠

;

c) Workforce Innovation and Opportunity Act (WIOA) requirements (Public Law 113-128);

d) Any other relevant state or federal laws and regulations specific to adult education.

2.2. Assumptions

This policy assumes the follow conditions are met in order to be fully implemented:

2.2.1. Assumptions Regarding the Offering

Full-term: The School provides educational activities at least 175 calendar days per fiscal year (EDC

@§ 47612.5⁠

(a)(1)).

Full-time: The School provides at least 64,800 instructional minutes per fiscal year (EDC

@§ 46201⁠

Classroom-based: The School provides at least 80 percent of the required annual instructional time at a facility used principally for classroom instruction (EDC

@§ 47612.5⁠

(e)(1)).

Certificated: The School provides immediate supervision and control of a certificated employee of the charter school while engaged in educational activities required of them for at least some part of each school day for which attendance is generated (EDC

@§ 47605⁠

(l)).

Workforce-oriented: The School is a WIOA training provider (Workforce Innovation and Opportunity Act, Public Law 113-128).

2.2.2. Assumptions Regarding the Student

Local: The Student is a California resident (EDC

@§ 48204⁠

Age-appropriate: The Student is at least 22 years of age (EDC

@§ 47612⁠

(b)).

In high school: The Student doesn’t have a high school diploma and is in pursuit of a high school diploma (EDC

@§ 47612.1⁠

Progressing: The Student is making

@Satisfactory progress⁠

towards the award of a high school diploma (EDC

@§ 47612.5⁠

(a)(3)).

Attending regularly: The Student attends at least 80 percent of the annual instructional minutes at a facility used principally for classroom instruction (EDC

@§ 47612.5⁠

(e)(1)).

2.3. Attendance Records

a) The School shall maintain written contemporaneous records that document all adult student attendance; (5 CCR

@§ 11960⁠

(a));

b) For the purposes of this policy and in compliance with 5 CCR

@§ 11960⁠

(a), the School's digital attendance records generated on the Highlands Brain app and and maintained through PowerSchool constitute the official "written contemporaneous records" of attendance;

c) Attendance records must be accurate, complete, and verifiable; (5 CCR

@§ 11960⁠

(a));

d) Records must be sufficient to allow for the accurate calculation of ADA. (EDC

@§ 47612⁠

);

e) The digital attendance records shall be securely backed up daily and shall be easily accessible for audit and review purposes, (5 CCR § 16020; § 16023).

2.4. ADA Calculation

a) ADA shall be calculated by dividing the School's total number of pupil-days of attendance by the number of calendar days on which school was taught in the School through the P2 and Annual apportionment periods. (5 CCR

@§ 11960⁠

(b));

b) No student shall generate more than one day of attendance in a calendar day. (5 CCR

@§ 11960⁠

(a)).

2.5. Attendance Reporting

a) The School shall submit P2 and Annual reports of attendance to the California Department of Education (CDE). (EDC

@§ 47612⁠

);

b) These reports must be supported by the School's contemporaneous attendance records. (5 CCR

@§ 11960⁠

(a));

c) The School shall also maintain any additional attendance reporting required for WIOA compliance. (WIOA § 116).

2.6. Multi-Track Calendar

If the School operates a multi-track calendar, it shall:

a) Calculate ADA separately for each track. (EDC § 47612(b));

b) Operate no more than five tracks. (EDC § 47612(b));

c) Operate each track for a minimum of 175 days. (EDC § 47612(b));

d) Provide the total number of instructional minutes as specified in Education Code section 47612.5 for each track. (EDC § 47612.5);

e) Ensure no track has less than 55 percent of its schooldays before April 15. (EDC § 47612(b)).

2.7. Age Requirements

a) The School shall only enroll and report ADA for students who are 22 years of age or older, in compliance with WIOA requirements. (EDC § 47612(b));

b) The School shall maintain documentation verifying the age of each enrolled student. (WIOA § 116).

2.8. School Day Reporting

a) The School shall accurately report the number of school days on the Annual attendance report. (5 CCR § 11960(b));

b) This report shall not include any emergency closure days unless approved through a Form J-13A. (EDC § 41422).

2.9. Audit Preparation

The School shall maintain all records and follow all procedures necessary to demonstrate compliance with attendance requirements during annual audits, including any specific requirements for adult education and WIOA programs. (EDC § 47612.5).

2.10. WIOA Compliance

a) The School shall maintain records and procedures that align with WIOA requirements for attendance and participation. (WIOA § 116);

b) The School shall ensure that attendance records support any WIOA performance indicators and reporting requirements. (WIOA § 116).

3. Objectives

The policy has objectives for the attendance record, the collection of records, and the procedures that generate them. These objectives are designed to ensure compliance with all relevant laws and regulations, particularly Education Code sections 47612 and 47612.5, and Title 5, California Code of Regulations, section 11960.

3.1. Attendance Record

a) Real and Unique: For each actively enrolled Student, for each section the Student is currently enrolled, for each calendar day when the School is in-session and provides educational activities — up to the current date, there exists one—and only one—attendance Record (hereafter "Record"). (EDC § 47612.5(a)(2));

b) Valid: Each Record indicates a valid code to signify whether the Student is "Present" or "Absent." A record with a 'null' value for the attendance code is not valid. (5 CCR § 11960);

c) Accurate: Each Record correctly indicates that the student was, in fact, Present (true positive case) or Absent (true negative case). This implies that there exist no false positive records and no false negative records. (EDC § 47612.5(a)(2));

d) Timely: Each Record is recorded the same calendar day of the attendance event. This ensures the validity and accuracy of the collection at any given time. (5 CCR § 11960).

3.2. Collection of attendance records

a) Complete: The collection contains one attendance record for each Student for each period enrolled for each calendar day when the School is in-session and provides educational activities. There are no missing Records up to the current date. (EDC § 47612.5(a)(2));

b) Easy to View: All authorized operators can view and monitor attendance records. (5 CCR § 11960);

c) Easy to Audit: The collection of attendance records can be easily shared with auditing parties. (5 CCR § 11960);

3.3. Standard operating procedures (SOPs)

a) Compliant: The set of SOPs sufficiently addresses all policy requirements pursuant to the relevant regulations and guidelines, including but not limited to EDC § 47612.5, § 48200, § 48205, § 48260, § 51747, and 5 CCR § 11960;

b) Concise: The SOPs are straightforward for each operator to understand and implement;

c) Appropriate: For each SOP operator, the SOPs are compatible with the scope of responsibility for each position occupied by the operator;

d) Complete: The procedures address all cases, all operators, and all scenarios.

3.4. WIOA Alignment

a) Performance Indicators: The attendance records support the calculation and reporting of WIOA performance indicators. (WIOA § 116);

b) Participant Tracking: The attendance system allows for tracking of individual participant attendance and progress as required by WIOA. (WIOA § 116);

c) Reporting Compatibility: The attendance data can be easily compiled and formatted for required WIOA reports. (WIOA § 116).

3.5. Adult Education Specific

a) Flexible Scheduling: The attendance system accommodates the potentially more flexible schedules of adult learners. (EDC § 47612.5);

b) Program Tracking: The system allows for tracking attendance across different adult education programs or courses. (EDC § 47612.5);

c) Progress Monitoring: The attendance records support monitoring of adult learners' progress towards their educational and career goals. (WIOA § 116).

4. Technology

The School uses both hardware and software to best meet all policy requirements and ensure compliance with Education Code sections 47612 and 47612.5, Title 5, California Code of Regulations, section 11960, and WIOA requirements.

4.1 Software

a) Highlands βrain app: The School uses a custom-built digital attendance accounting application to support attendance generation and management, hereafter called "βrain app." All students and staff are required to have the βrain app installed on their device and to be logged-in daily. The application is available for all Android and iOS mobile devices. It is already pre-installed on all school-issued devices. (EDC § 47612.5(a)(2));

b) Powerschool: The School uses a student information system (SIS) to report attendance records in the form of ADA to the CDE for apportionment. Attendance records approved by the certificated staff on the βrain app are sent to Powerschool for reporting purposes. (EDC § 47604.4);

c) WIOA Reporting Module: The School's software includes a module specifically designed to generate reports required by WIOA, ensuring that attendance data can be easily compiled and formatted for WIOA compliance. (WIOA § 116).

4.2 Hardware

a) Tap-enabled Student Check-in Stations: Each classroom includes at least one check-in station. The βrain app enables a 'tap'-based classroom check-in method for students using near-field communication (hereafter "NFC") functionality. When the Student touches their mobile device onto an NFC tag in the classroom, the βrain app generates a provisional attendance record for the certificated staffer to evaluate after the class session. (5 CCR § 11960);

b) Mobile Device: Each operator is required to bring an NFC-enabled mobile device to class daily. The School offers an acceptable mobile device to all students and staff at no cost. Each operator may use the school-issued device or a personal device. (5 CCR § 11960).

4.3 Data Security and Privacy

The School is committed to protecting the privacy and security of student attendance data in compliance with the Family Educational Rights and Privacy Act (FERPA) and other applicable laws. The following measures are in place to ensure data security and privacy:

a) Encryption: All attendance data is encrypted both in transit and at rest using industry-standard encryption protocols. This includes data stored in the Brain app, during transmission to the School's servers, and in the PowerSchool SIS. (FERPA, 20 U.S.C. § 1232g; 34 CFR Part 99);

b) Access Control: The system implements role-based access control to ensure that only authorized personnel can view, input, or modify attendance data. Access levels are as follows:

Students: Can view only their own attendance records;

Certificated Staff: Can view and modify attendance records for their assigned classes;

Attendance Clerks: Can view all attendance records and create provisional records;

Administrators: Have full access to all attendance data (FERPA; 5 CCR § 11960);

c) Audit Trail: The system maintains a detailed audit trail of all changes to attendance records, including the time, date, and user who made the change. This audit trail is preserved for a minimum of five years. (5 CCR § 11960)

d) Data Minimization: Only necessary attendance data is collected and stored, in accordance with the principle of data minimization. (FERPA)

e) Data Retention and Destruction: Attendance records are retained for a period of five years after the end of the school year. After this period, records are securely destroyed in accordance with FERPA guidelines. (FERPA; 5 CCR § 11960)

f) Third-Party Data Sharing: Any sharing of attendance data with third parties (such as WIOA partners) is done in compliance with FERPA regulations. Data sharing agreements are in place with all third parties, specifying the purpose of data sharing, the data elements shared, and the security measures in place. (FERPA)

g) Privacy Notifications: Students are provided with annual notifications of their rights under FERPA, including the right to inspect their education records and the circumstances under which their records may be disclosed. (FERPA)

h) Staff Training: All staff members with access to attendance data receive annual training on data privacy and security procedures, including FERPA compliance. (FERPA; 5 CCR § 11960)

i) Incident Response Plan: The School maintains an incident response plan for addressing potential data breaches, including procedures for notification of affected individuals and relevant authorities. (FERPA)

j) Regular Security Audits: The School conducts regular security audits of its attendance data systems to identify and address potential vulnerabilities. (5 CCR § 11960)

k) Mobile Device Management: For school-issued devices, mobile device management (MDM) software is used to ensure that devices can be remotely wiped if lost or stolen, protecting any locally stored attendance data. (FERPA)

l) Secure Communication: Any communication regarding student attendance that includes personally identifiable information is conducted through secure, encrypted channels. (FERPA)

By implementing these measures, the School ensures the confidentiality, integrity, and availability of student attendance data while maintaining compliance with all relevant laws and regulations.

4.4 Backup and Recovery

a) Regular Backups: The attendance data is backed up daily to prevent data loss. (5 CCR § 11960);

b) Off-site Storage: Backups are stored in a secure off-site location to ensure data recovery in case of on-site emergencies. (5 CCR § 11960);

c) Recovery Testing: Regular tests are conducted to ensure the effectiveness of data recovery procedures. (5 CCR § 11960).

4.5 System Integration

a) SIS Integration: The attendance system is fully integrated with the School's Student Information System to ensure seamless data flow and reduce manual data entry errors. (EDC § 47612.5);

b) WIOA System Compatibility: The attendance system is designed to be compatible with any required WIOA reporting systems, allowing for efficient data transfer when necessary. (WIOA § 116).

4.6 Training and Support

a) User Training: Regular training sessions are provided to all staff on the use of the attendance technology. (5 CCR § 11960);

b) Technical Support: Ongoing technical support is available to address any issues with the attendance technology promptly. (5 CCR § 11960);

c) Documentation: Comprehensive user guides and documentation are maintained and regularly updated for all attendance-related technology. (5 CCR § 11960).

5. Responsibilities

There are three types of operators for generating attendance — Student, Certificated staffer, and Attendance clerk. Each has distinctive responsibilities, enacted through policies.

5.1. Student

A Student is an actively enrolled pupil of the School.

a) Attend Class Daily: Each Student is responsible for attending class daily (California Education Code § 48200);

b) Receive Adequate Instruction Time: Each Student is responsible for staying for the duration of instructional time provided each calendar day;

c) Use the app. Each Student is responsible for bring a mobile device with the Brain app installed and be logged in under his or her own account. This can either be a school-issued mobile device or a personal mobile device;

d) Demonstrate Present Attendance: Each Student is responsible for demonstrating their Present status for each section daily through the methods provided by the School;

e) Monitor Attendance: Each Student is responsible for monitoring their own attendance Records to ensure the Records are valid, accurate, and complete.

5.2. Certificated staffer

A Certificated staffer is an individual employed by the School who holds a valid teaching certificate or credential, qualifying them to teach in a public school setting. In most cases, the Certificated staffer operator is the “Section Teacher.” This applies to the primary teacher or co-teacher assigned to the Section. The Section Teacher is responsible for the attendance records for every Student in their roster. Only a certificated staffer may submit attendance records to the School’s SIS for reporting (California Education Code § 47605(l)).

a) Monitor: The Section Teacher is responsible for monitoring the collection of Records;

b) Assess: The Section Teacher is responsible for assessing the validity and accuracy of each provisional Record. The Section Teacher is authorized and required to remove any Records they believe are created in error;

c) Adjust: The Section Teacher is responsible for modifying the Record whenever it is required to be unique, valid, and accurate;

d) Submit: The Section Teacher is responsible for submitting all approved attendance Records daily;

e) Confirm: The Section Teacher is responsible for checking the SIS on a regular basis to confirm the Records were delivered successfully.

5.3. Attendance clerk

An Attendance clerk is a school staff member responsible for supporting the Certificated staffers in recording and managing provisional Records. The most common case of the Attendance clerk operator is the classroom “Paraeducator” who works directly and synchronously with the Section Teacher. Example alternative Attendance clerks are counselors or event organizers who directly supervise the Student engaging in educational activities provided by the School, sufficient for instructional minutes. Attendance clerks are only authorized to create provisional Records; all Records are approved by a Certificated staff only. Attendance clerks are not authorized to adjust or submit attendance logs (California Education Code § 45349).

a) Create a Provisional Record: The Attendance clerk may create a Record for the Certificated staffer to review;

b) Recommend: The Attendance clerk may recommend —to Certificated staffers— any adjustments to existing Records.

6. Policies and SOPs

6.1 Daily Attendance Recording

Requirement Reference: 2.3(a), 2.3(b), 3.1(a), 3.1(b)

Policy: All students are required to record their attendance daily using the Highlands Brain app. Students must check in for each class session they attend.

Procedure:

a) Student: Use the NFC-enabled check-in stations in each classroom to record attendance via the Brain app within the first 15 minutes of the class start time;

c) Attendance Clerk: Monitor daily check-ins and flag any inconsistencies for follow-up;

b) Certificated Staffer: Review and confirm attendance records at the end of each class session.

6.2 Absence Reporting

Requirement Reference: 2.3(b), 3.1(c), 3.1(d)

Policy: Students must report all absences through the Highlands Brain app as soon as possible, preferably before the start of the missed class.

Procedure:

a) Student: Select the conversation with your teacher in Chat module of the Brain app to notify the school of absence, providing a reason and expected return date.

b) Certificated Staffer: Review reported absences daily and update attendance records accordingly.

c) Attendance Clerk: For absences longer than three consecutive days, contact the student to request additional documentation if necessary.

6.3 Tardiness Requirement

Reference: 2.3(b), 3.1(c), 3.2(a)

Policy: Students arriving more than 15 minutes late to a class will be marked tardy in the attendance system.

Procedure:

a) Student: Check in using the Brain app upon late arrival, regardless of time;

b) Certificated Staffer: Verify tardy records at the end of each class session;

c) Attendance Clerk: Generate weekly reports on tardiness patterns for administrative review.

6.4 Make-up Work

Requirement Reference: 2.9(b), 3.5(c)

Policy: Students are responsible for completing all missed assignments due to absences.

Procedure:

a) Student: Contact instructor through the Brain app to request missed assignments;

b) Certificated Staffer: Provide make-up work and set reasonable deadlines for completion through the Brain app;

c) Attendance Clerk: Monitor completion of make-up work and update attendance records if necessary.

6.5 Chronic Absenteeism and Attendance Intervention

Requirement Reference: 2.9(a), 2.9(b), 3.5(c)

Policy: The school will intervene when a student's attendance falls below 80% in any given month.

Procedure:

a) Attendance Clerk: Monitor attendance rates and flag students below 80% attendance;

b) Certificated Staffer: Contact flagged students to discuss barriers to attendance and provide support;

c) Student: Collaborate with staff to develop an attendance improvement plan;

d) Administrator: Review and approve attendance improvement plans.

6.6 WIOA Attendance Reporting

Requirement Reference: 2.4(c), 2.9(a), 2.9(b), 3.4(a), 3.4(b), 3.4(c)

Policy: The school will maintain attendance records that support WIOA performance indicators and reporting requirements.

Procedure:

a) Attendance Clerk: Generate WIOA-compliant attendance reports monthly using the Brain app;

b) Administrator: Review and submit WIOA reports as required by guidelines;

c) Certificated Staffer: Ensure all attendance data is accurately recorded to support WIOA reporting.

6.7 Attendance Appeals

Requirement Reference: 2.2(b), 3.1(c), 3.2(b)

Policy: Students have the right to appeal attendance-related decisions.

Procedure:

a) Student: Submit an appeal through the Brain app within five business days of the disputed attendance record;

b) Attendance Clerk: Compile relevant information for the attendance committee;

c) Administrator: Convene the attendance committee to review appeals within ten business days;

d) Certificated Staffer: Participate in the attendance committee as required.

6.8 Attendance Incentives

Requirement Reference: 2.9(b), 3.5(c)

Policy: The school will recognize and reward excellent attendance.

Procedure:

a) Attendance Clerk: Generate monthly reports of students with perfect attendance;

b) Administrator: Review and approve attendance recognition and rewards;

c) Certificated Staffer: Acknowledge students with excellent attendance in class;

d) Student: Track personal attendance goals through the Brain app.

6.9 Attendance for Various Instructional Activities

Requirement Reference: 2.2(a), 2.2(b), 3.5(a), 3.5(b)

Policy: Attendance will be recorded for all types of approved instructional activities.

Procedure:

a) Certificated Staffer: Record attendance for off-site activities (internships, field trips) using the Brain app;

b) Student: Log in to the Brain app for online components to track participation;

c) Attendance Clerk: Verify and reconcile attendance for various instructional activities weekly.

6.10 Early Departures

Requirement Reference: 2.3(b), 3.1(c), 3.2(a)

Policy: Students leaving class more than 15 minutes before the scheduled end time will be marked as an early departure.

Procedure:

a) Student: Use the Brain app to check out when leaving early;

b) Certificated Staffer: Verify early departure records at the end of each class session;

c) Attendance Clerk: Generate weekly reports on early departure patterns for administrative review.

7. Accountability

To ensure adherence to the Attendance Generation Policy, the following consequences are established for non-compliance. These consequences are aligned with each policy and specified for each operator type.

7.1 Daily Attendance Recording

Policy 6.1

a) Student:

First offense: Verbal warning and reminder of attendance policy;

Second offense: Written warning in student file;

Third offense: Mandatory meeting with counselor and potential loss of privileges;

b) Certificated Staffer:

First offense: Verbal warning;

Second offense: Written warning in personnel file;

Third offense: Performance improvement plan and potential impact on evaluation;

c) Attendance Clerk:

First offense: Verbal warning;

Second offense: Written warning in personnel file;

Third offense: Retraining and potential reassignment of duties;

12.2 Absence Reporting (Policy 6.2)

a) Student: - Failure to report absence: Marked as an unexcused absence, potentially affecting academic standing

b) Certificated Staffer: - Failure to review reported absences: Verbal warning, escalating to written warning for repeated offenses

c) Attendance Clerk: - Failure to follow up on extended absences: Verbal warning, escalating to written warning for repeated offenses

12.3 Tardiness (Policy 6.3)

a) Student: - Accumulation of tardies: May result in mandatory attendance counseling and potential impact on course grades

b) Certificated Staffer: - Failure to accurately record tardies: Verbal warning, escalating to written warning for repeated offenses

c) Attendance Clerk: - Failure to generate or inaccurate tardiness reports: Verbal warning, escalating to written warning for repeated offenses

12.4 Make-up Work (Policy 6.4)

a) Student: - Failure to complete make-up work: May result in lower grades or incomplete course status

b) Certificated Staffer: - Failure to provide make-up work: Verbal warning, escalating to written warning for repeated offenses

c) Attendance Clerk: - Failure to monitor make-up work completion: Verbal warning, escalating to written warning for repeated offenses

12.5 Chronic Absenteeism and Attendance Intervention (Policy 6.5)

a) Student: - Continued chronic absenteeism despite intervention: May result in program dismissal, subject to appeal process

b) Certificated Staffer: - Failure to implement intervention plan: Written warning and mandatory retraining

c) Attendance Clerk: - Failure to flag chronic absenteeism: Written warning and mandatory retraining

d) Administrator: - Failure to review/approve intervention plans: Written warning and potential disciplinary action

12.6 WIOA Attendance Reporting (Policy 6.6)

a) Attendance Clerk: - Inaccurate WIOA reports: Written warning and mandatory retraining

b) Administrator: - Failure to review/submit WIOA reports: Written warning and potential disciplinary action

c) Certificated Staffer: - Inaccurate attendance recording affecting WIOA reporting: Written warning and mandatory retraining

12.7 Attendance Appeals (Policy 6.7)

a) Student: - Abuse of appeal process: May result in loss of appeal privileges

b) Attendance Clerk: - Failure to properly process appeals: Verbal warning, escalating to written warning for repeated offenses

c) Administrator: - Failure to convene attendance committee timely: Written warning

d) Certificated Staffer: - Failure to participate in attendance committee: Verbal warning, escalating to written warning for repeated offenses

12.8 Attendance Incentives (Policy 6.8)

a) Attendance Clerk: - Failure to generate accurate attendance reports for incentives: Verbal warning, escalating to written warning for repeated offenses

b) Administrator: - Failure to implement incentive program: Written warning

c) Certificated Staffer: - Failure to acknowledge excellent attendance: Verbal reminder, escalating to written warning for repeated offenses

12.9 Attendance for Various Instructional Activities (Policy 6.9)

a) Certificated Staffer: - Failure to record attendance for off-site activities: Written warning and mandatory retraining

b) Student: - Failure to log attendance for online components: Verbal warning, potentially affecting course participation credit

c) Attendance Clerk: - Failure to reconcile attendance for various activities: Verbal warning, escalating to written warning for repeated offenses

12.10 Early Departures (Policy 6.10)

a) Student: - Excessive early departures: May result in mandatory attendance counseling and potential impact on course grades

b) Certificated Staffer: - Failure to accurately record early departures: Verbal warning, escalating to written warning for repeated offenses

c) Attendance Clerk: - Failure to generate or inaccurate early departure reports: Verbal warning, escalating to written warning for repeated offenses

Note: All consequences are subject to due process and may be appealed through appropriate channels. Repeated violations may result in more severe consequences, up to and including dismissal from the program (for students) or termination of employment (for staff), in accordance with applicable laws and regulations.

8. Periodic Review

To ensure ongoing compliance with changing regulations and to maintain the effectiveness of our attendance procedures, Highlands Community Charter School establishes the following periodic review process for this Attendance Generation Policy:

8.1 Annual Review

a) Timing: A comprehensive review of the entire policy will be conducted annually, typically during the summer break before the start of a new academic year;

b) Review Committee: A committee consisting of the following members will conduct the review:

School Administrator

Lead Certificated Staff Member

Attendance Clerk

IT Representative

Brain App Representative

WIOA Compliance Officer

Legal Counsel (as needed)

c) Review Criteria: The committee will assess the policy based on:

Compliance with current federal, state, and local regulations

Effectiveness in accurately tracking and reporting attendance

User feedback from staff and students

Technological advancements and potential improvements

Alignment with WIOA requirements and best practices

Data security and privacy considerations

d) Outcome: The committee will produce a report detailing:

Recommended policy updates

Implementation plan for approved changes

Training needs for staff and students

8.2 Quarterly Check-ins

a) Timing: Brief reviews will be conducted at the end of each academic quarter.

b) Participants: School Administrator, Lead Certificated Staff Member, and Attendance Clerk

c) Focus: These check-ins will address:

Any immediate issues or concerns with attendance procedures

Preliminary data on attendance trends

Feedback from staff and students

Any recent or upcoming regulatory changes

d) Outcome: A brief summary of findings and any necessary immediate actions

8.3 Continuous Monitoring

a) The School Administrator and Attendance Clerk will continuously monitor:

Changes in relevant laws and regulations

CDE bulletins and updates

WIOA policy changes

Technological advancements in attendance tracking

b) Any significant changes identified through continuous monitoring will trigger an ad-hoc review of relevant policy sections.

8.4 Stakeholder Feedback

a) Annual Surveys: Staff and students will be surveyed annually on the usability and effectiveness of attendance procedures;

b) Suggestion System: A system will be maintained for staff and students to submit suggestions or report issues with attendance procedures at any time.

8.5 External Audit Alignment

a) The policy review process will consider findings from the most recent annual audit related to attendance;

b) Any audit recommendations will be incorporated into policy updates.

8.6 Version Control and Documentation

a) Each review, whether annual, quarterly, or ad-hoc, will be documented;

b) The policy document will maintain a version history, noting:

Date of update

Summary of changes

Approving authority

c) All stakeholders will be notified of policy updates, with changes clearly highlighted.

8.7 Training and Implementation

a) Following any significant policy updates, a training plan will be developed and implemented for all affected staff and students;

b) Updated procedures will be clearly communicated through multiple channels, including the Brain app, email notifications, and staff meetings.

8.8 Board Approval

a) Any substantial changes to the policy will be presented to the School's Board for review and approval;

b) The Board will be provided with an annual summary of policy reviews and updates.

By implementing this periodic review process, Highlands Community Charter School ensures that its Attendance Generation Policy remains current, compliant, and effective in meeting the needs of the school, its students, and regulatory requirements.