Attendance Compliance

Dynamic Policy

A dynamic version of the Attendance Generation Policy.

Last edited 70 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

2. Requirements

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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.

View 2 of Policies

View 2 of Policies

Addressed Requirements

Title

Policy

Policy terms

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

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

Daily Attendance Recording

All students are required to record their attendance daily using the Highlands Brain app. Students must check in for each course they attend each day.

Present attendance

Absence Reporting

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

Tardiness Requirement

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

Absence

Make-up Work

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

Absence

Make-up work

Chronic Absenteeism and Attendance Intervention

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

Tardy

WIOA Attendance Reporting

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

Chronic absenteeism

Attendance Appeals

Students have the right to appeal attendance-related decisions.

Truancy

Attendance Incentives

The school will recognize and reward excellent attendance.

Reward

Attendance for Various Instructional Activities

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

Early Departures

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

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