California Community Colleges System Office CACCRAO Annual Conference Palm Springs, CA “Step by Step” Current Activities and Issues in Attendance Accounting.

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California Community Colleges System Office CACCRAO Annual Conference Palm Springs, CA “Step by Step” Current Activities and Issues in Attendance Accounting and Reporting Presented by Elias Regalado May 1, 2007

“Step by Step” AGENDA n S.B. 361 Implementation –What is S.B. 361? –Goals –Major Components –Current Status –Addendums to CCFS-320 n Title 5, Chapter 6 (Curriculum and Instruction) Regulation Review n Academic Calendars & Related Topics n Current Activities and Issues * Unless otherwise indicated, all legal citations refer to California Code of Regulations, Title 5

S.B. 361 – New Funding System n What is S.B. 361? n As of 10/1/06 (Urgency Statute), replaced Program Based Funding with a new methodology for the allocation of apportionment revenue beginning with FY (Education Code §§ / ) n S.B. 361 also resulted in enhanced funding for qualified Noncredit courses (Career Development and College Preparation – CDCP – Noncredit Courses) n Categorical programs continue to be funded separately through Annual Budget Act n New Funding System Goals: n Fairness, Simplicity, and Predictability

S.B. 361 – New Funding System (cont.) n Major Components: n Basic Allocation: Based on number and size of college campuses and centers  Basic Allocation Base Rates for Single-College Districts:  FTES >= 20,000$5,000,000  10,000 <= FTES < 20,000$4,000,000  FTES < 10,000$3,000,000  Basic Allocation Base Rates per College for Multi-College districts:  FTES >= 20,000$4,000,000  10,000 <= FTES < 20,000$3,500,000  FTES < 10,000$3,000,000

S.B. 361 – New Funding System n Major Components (Cont.): n Basic Allocation (Cont.) n Basic Allocation Base Rates for Centers  Approved CPEC centers: FTES >= 1,000$1,000,000  “ Grandparented” Centers:  FTES >= 1,000$1,000,000  750 <= FTES < 1,000 $750,000  500 <= FTES < 750 $500,000  250 <= FTES < 500 $250,000  100 <= FTES < 250 $125,000

S.B. 361 – New Funding System n Major Components (Cont.): n Basic Allocation (Cont.)  Basic Allocation Center Types (two types):  California Post Education Commission (CPEC) Approved having at least 1,000 FTES  “Grandfathered” Centers: Not meeting current CPEC standards as of July 1, 2006, but previously approved by CPEC as eligible for state capital facilities or in existence as a center prior to CPEC’s establishment.

S.B. 361 – New Funding System n Major Components (Cont.): n Basic Allocation (Cont.)  Basic Allocation augmentation for Rural Colleges  Criteria for augmentation of $500,000:  Service area population density less than half the statewide average (currently 217 people/square mile)  Credit FTES less than 5,000  Single College District

S.B. 361 – New Funding System  Major Components (Cont.):  Equalized FTES funding rates beginning in :  Credit funding rate is $4,367 - to be adjusted by cola in subsequent years  Noncredit funding rate is $2,626 - to be adjusted by cola in subsequent years  Career Development and College Preparation Noncredit may be funded at $3,092 – to be adjusted by cola in subsequent years

S.B. 361 – New Funding System  Major Components (Cont.):  Career Development and College Preparation (CDCP) Noncredit Courses n : $30 million is appropriated to fund the CDCP Noncredit incremental $466 increase above the standard Noncredit rate of $2,626 n If $30 million is not sufficient to fully fund available CDCP Noncredit, the CDCP funding will be deficited

S.B. 361 – New Funding System n Implementation: n On January 16, 2007, BOG adopted two sets of emergency regulations to be consistent with underlying statute (S.B. 361) and Education Code n First set made changes in the basic formula for the allocation of general apportionment revenue n Second set dealt with enhanced funding for qualified CDCP Noncredit courses n Emergency regulations In effect for 180 days or 6 months

S.B. 361 – New Funding System n Implementation (Cont.) n First Principal Apportionment (P1) calculated pursuant to the revised funding provisions of S.B. 361 as incorporated in emergency Title 5 regulations n Efforts under way to begin development of permanent regulations, but are not anticipated to be legally effective until early August. n To bridge the gap between emergency and permanent regulations, on March 5, 2007, BOG extended emergency regulations to August 31, 2007

S.B. 361 – New Funding System n Implementation (Cont.) n CCFS-320 Addendums n CDCP Noncredit FTES n Noncredit Certificate Applications due Feb. 28, 2007 for purposes of the Second Principal Apportionment (Certificate of Completion and Certificate of Competency) n Necessary for enhanced funding allocation and S.B. 361 reporting requirements n Certificate and Course data to be submitted annually (March 1) to Legislature and Department of Finance n Amount of FTES claimed by districts n Specific Program and Course Titles n Number of courses receiving enhanced funding

S.B. 361 – New Funding System n Implementation (Cont.) n CCFS-320 Addendums (Cont.) n CDCP Noncredit FTES (Cont.) n District Applications Status (P-2): n Approx. 180 applications approved (24 districts) n Approx. 1,200 Courses n Reporting Process n FTES (Annualized) n Number of Course Sections (Annualized) n Data entered at the district level and not disaggregated by college n Data is “supplemental” information and will be considered a subset of the total FTES reported on the CCFS-320

S.B. 361 – New Funding System n Implementation (Cont.) n CCFS-320 Addendums n Center FTES Reporting n Districts with S.B. 361 Grandparented centers certified each center’s total Annual FTES, as of Recal (manual reporting process) n Based on reported information, Basic Allocation funding for CPEC Approved and Grandparented Centers started with the First Principal Apportionment n Future Reporting Periods: Annual and Recal only (web- based reporting process)

Title 5, Chapter 6 – Regulation Review n Background n System Office staff and a subcommittee of the Systemwide Advisory Committee on Curriculum currently working on a comprehensive review of Title 5, Chapter 6, which includes provisions related to: n Curriculum standards n Course and program approval n Course repetition n Limit on times a student may withdraw from a course n Field trips and excursions n Distance Education/Independent Study courses n Offering courses outside of district boundaries n Academic Calendars

Title 5, Chapter 6 – Regulation Review n Status n First Draft of proposed revisions sent to Districts on March 26, 2007 n Second Draft sent April 9, 2007 n System Office presented draft to Consultation Council on April 19, 2007 n Draft includes an index to easily track new, repealed, and relocated sections. n Would go into effect in August if approved by BOG in July 2007 n Comments or questions about proposed revisions should be submitted to Ralph Black, Assistant General Counsel, at:

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting n L imitation on “W”s in one course (§§ and ) n A student shall not be permitted to receive more than three (3) “W” symbols on his or her record for enrollment in the same course n A student who enrolls again in a course after already having already received three “W”s in the same course shall receive a grade or a different nonevaluative symbol, unless the student withdraws from the course prior to the end of the fourth week of instruction or 30 percent of the term, whichever is less, or such shorter period as established by the district

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n L imitation on “W”s in one course (§§ and ) (Cont.) n District may not claim apportionment for the attendance of a student in a credit course if the “W” symbol has been previously been assigned to that student for that same course on three or more occasions n Would go into effect in August if approved by the Board in July, so the first term affected would be Fall 2007 n District would need to look back for “W”s issued in the same course prior to that

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n Increase in “Repeats” allowed for substandard grades (Proposed §§ 55040, 55041, and 58161) n District may allow a student to repeat a course two times in an effort to alleviate substandard academic work (only one repetition currently permitted) n District may, upon petition by the student, permit a third repetition of a course in which substandard academic work has been recorded, provided the district finds that there are extenuating circumstances (accidents, illness, or other circumstance beyond the control of the student) [THIS REPETITION WOULD NOT BE ELIGIBLE FOR APPORTIONMENT] n This two repetition limit also applies where a student is permitted to repeat a course by petition where substandard work was NOT recorded pursuant to proposed Section 55041(e) (district finds that there are extenuating circumstances)

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n Increase in “Repeats” allowed for substandard grades (Proposed §§ 55040, 55041, and 58161) (Cont.) n “Substandard academic work” occurs when grading symbols “D,” “F,” “FW,” “NP” or “NC” has been recorded n Optional, so districts can implement it when and if they wish n Repetitions beyond the limits stated here are permitted, but may not be claimed for apportionment n District may allow the previous grade and credit to be disregarded in computing the student’s GPA each repetition

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n Repetitions for Noncredit courses (Proposed § 58161(i)) n The attendance of a student repeating a Noncredit course may be claimed for apportionment if the district documents that, during the previous enrollment in the course, the student made measurable progress toward, but has not yet fully achieved, the learning objectives specified for the course n District must maintain such documentation as a Class 3 disposable record basic to audit n A student is considered to have taken or repeated a Noncredit course when he or she enrolls in a Noncredit course on or after 7/1/07 and completes at least 30% of the course hours n Chancellor is directed to report to BOG by 1/15/09 on appropriate limitations for Noncredit course repetitions

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n Prohibition in enrolling in same course during the same semester or session (Proposed § 55007(a)) n Students may not simultaneously enroll in two or more sections of the same course during the same term n Students needing additional instruction in the subject matter while enrolled in a course may be referred to: n Individualized tutoring pursuant to § n Supplemental learning assistance pursuant to §§ and 58164

Title 5, Chapter 6 – Regulation Review n Proposed Changes Impacting Attendance Accounting & Reporting (cont.) n Prohibition in enrolling in overlapping courses (Proposed § 55007(b)) n Students may not enroll in two or more courses where the meeting times for the courses overlap, unless the district establishes a mechanism for ensuring the following requirements are met: n The student provides a sound justification n Appropriate district official approves the schedule n The college maintains documentation describing the justification and showing that the student made up the hours not attended under the supervision of the instructor of the course during the same week

Academic Calendars & Related Topics n Concept Paper The Concept Paper is a joint product of the College Finance and Academic Affairs Divisions of the System Office and was developed collaboratively with CIO leaders Objective is to enhance dialog between the System Office and the districts on standardization strategies related to course scheduling, flex calendars, and academic calendar compression The Concept Paper includes background/historical information, definitions, problem descriptions, possible resolution actions, and a conclusion with expected next steps

Academic Calendars & Related Topics n Concept Paper (Cont.) The Concept Paper was formally presented by CIO leaders at the Joint CIO/CSSO conference of March , The Concept Paper has also been presented to Consultation Council and the Fiscal Standards and Accountability Committee Feedback has been solicited for an expected future communication from the System Office to formalize any final guidance In the interim, and in the interest of a prudent and timely review of current compressed calendar applications, the guidelines included in the concept paper are currently being applied to the review and approval process for compressed calendar applicants

Academic Calendars & Related Topics n Concept Paper (Cont.) Going forward, we will continue the development of the compressed calendar guidelines internally The objective continues to be to clarify identified issues and current Title 5 regulations, and not create new regulations Once work is completed, the Academic Senate will be provided an opportunity to provide input on the finalized guidelines prior to bringing them back to the Consultation Council for discussion

Academic Calendars & Related Topics n Changes in Academic Calendar Configuration – Application Process n Per § 55720, prior to any change in academic calendar configuration, a district shall obtain approval from the System Office n District must demonstrate compliance with 175-Day Rule (§§ and 58142) and address state aid implications n District must provide educational implications, positive and negative, of the proposed change and other relevant information (studies, surveys, analysis, etc) n Questions regarding Academic Calendar changes should be directed to Elias Regalado, System Office

Attendance Accounting Issues n District Attendance Accounting Procedures as Req. by §58030 n Board adopted procedures that will document all: n Course enrollment n Student attendance n and Disenrollment n Procedures GOAL: Accurate and timely attendance and contact hour data reflective of internal controls n Such procedures shall include rules for retention of support documentation to enable independent determination of the accuracy of FTES reported for apportionment purposes

Attendance Accounting Issues n District Attendance Accounting Procedures as Req. by § (Cont.) n Should cover other critical attendance accounting areas, including: n Clearing of census rosters n Overlapping course attendance n TBA Contact Hours (To Be Arranged) n Tracking of cancelled classes n Proper scheduling of courses relative to attendance accounting procedures n Contact Hour calculations n Course repetition n Should be regularly reviewed to assure compliance with all current requirements

Attendance Accounting Issues n Internal Control Systems n As previously noted, district Attendance Accounting Procedures as required by § shall be structured as to provide for internal controls n Internal controls provide reasonable assurance for the reliability of: n Attendance and contact hour data n Safeguarding of records (physical records as well as information system data files and applications) n And compliance with laws and regulations n Due to direct relationship to Apportionment eligibility, internal controls in this area are critical

Attendance Accounting Issues n Internal Control Systems (cont.) n If district is subject to a comprehensive audit/review relative to FTES claims, MIS and Admissions and Records Office internal control systems, and possibly others, will be reviewed for student attendance monitoring and accountability n Procedures applicable to internal control systems should be as specific as possible, including indicating which group or department head will provide leadership and ongoing oversight n These procedures should make special mention of internal controls applicable to information systems

Attendance Accounting Issues n Internal Control Systems (cont.) n Internal control procedures applicable to information systems also ensure that: n Data processing diagnostics and errors are noted and resolved n Applications and functions are processed according to established schedules and reporting periods n File backups are taken at appropriate intervals n Recovery procedures for data processing failures are established n Actions of computer operators and system administrators are reviewed n Primary resources concerning internal controls include the district CBO and the Internal Auditor

Attendance Accounting Issues n Affirmative Confirmation of Students “Actively Enrolled” n § requires districts to clear the course rolls of inactive enrollment as of each census day for any student who has been identified as a “no show”, any student who has officially withdrawn from the course, and any student who has been dropped from the course n District must drop students that are no longer participating in the course, except if there are extenuating circumstances n “No longer participating” includes, but is not limited to, excessive unexcused absences but must relate to nonattendance

Attendance Accounting Issues n Affirmative Confirmation of Students “Actively Enrolled” n Districts must have affirmative confirmation of students actively enrolled in census courses as of each census day in order to factually comply with tabulation requirements provided by § and to properly report FTES for apportionment purposes n Legal advisory will be prepared addressing this issue

Attendance Accounting Issues n Miscellaneous Issues & Reminders n Course contact hours claimed for apportionment must be consistent with corresponding course outlines (§ 58050) n Relationship of hours to units must be based on Board approved policy (§§ 55002; 58050) n Independent Study Attendance Accounting procedure exception for Independent Study Labs (§ 58009)

Attendance Accounting Issues n Miscellaneous Issues & Reminders n CCFS-320 “F” (Flex) Factors must be thoroughly reviewed prior to certification (§ 55729) n Local holidays/college closures may impact applicability of attendance accounting procedures, which may result in less apportionment (§ ) n Cancelled Census classes should not be claimed for apportionment (§§ 58050;58051) n Be sure to fully report Basic Skills FTES

Attendance Accounting Issues n Miscellaneous Issues & Reminders n Contracted District Audit Manual (CDAM) to be released soon n Emergency Conditions Request (CCFS-313, § 58146) n Timely submission of CCFS-320 is critical to apportionment process and State Budget development (§ ) n Feedback on recent CCC Confer training for CCFS-320 Addendums

Questions/Comments