Attendance Accounting Webinar:
Courses with Hours by Arrangement
Course Repetition and Withdrawal
CCC Chancellor’s Office
November 10, 2011
John Mullen, Senior Consultant
Strata Information Group
Elias Regalado, Specialist, Allocations
Chancellor’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
Advice (Legal Advisory 08-02), October 1,
2008
 To Be Arranged (TBA) Hours Follow-up
Memorandum, January 26, 2009
 Second To Be Arranged (TBA) Hours Followup 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 Mullen
Strata Information Group
Phone: 650.533.6850
Email: mullen@sigcorp.com
Elias Regalado
Fiscal Services, Chancellor’s Office
Phone: 916.445.1165
Email: eregalad@cccco.edu