NCDPI response to OSA report: Student Attendance and Truancy Analysis 2020-2021 School Year
North Carolina Public Schools sent this bulletin at 10/12/2023 11:22 AM EDT
The North Carolina Department of Public Instruction (NCDPI) disagrees with the premise and content of the report issued by the Office of the State Auditor (OSA) entitled, Student Attendance and Truancy Analysis 2020-2021 School Year. Given the unprecedented nature and magnitude of errors of this audit, NCDPI felt it necessary to respond directly to this egregious report.
OSA went beyond the scope of the General Assembly’s request and because OSA staff did not understand the nomenclature regarding school attendance policies and therefore the data, six school districts and NCDPI are being improperly censured.
Background
SL 2021-180, passed November 18, 2021, provided funding to OSA for the purpose of conducting an analysis of the policies schools put in place during the 2021-2022 school year while schools were dealing with the impact of the COVID-19 pandemic.
$350,000 to contract with the State Auditor, in response to the COVID-19 pandemic, to perform detailed analyses of the attendance and truancy policies and procedures for the 2021-2022 school year of at least two small, two medium-sized, and two large local school administrative units, selected randomly by the State Auditor. The State Auditor may contract with third-party entities, as needed, for services related to the analyses. No later than June 30, 2022, the State Auditor shall report to the Joint Legislative Education Oversight Committee, the Senate Appropriations Committee on Education/Higher Education, the House Appropriations Committee on Education, and the Fiscal Research Division on the results of the analyses and any recommendations to remediate student absenteeism.
-Session Law 2021-180, Section 7.27(a)(14)
Through SL 2021-180 the legislature asked OSA, “to perform detailed analyses of the attendance and truancy policies and procedures for the 2021-2022 school year … [and] report … on the results of the analyses and any recommendations to remediate student absenteeism.”
The issues of attendance accuracy, chronic absenteeism, truancy, and “missing students” during the COVID-19 pandemic and remote learning were well-documented and therefore known by school districts and the general public[1],[2]. Rates of chronic absenteeism nearly doubled nationwide and in North Carolina during the COVID-19 pandemic and are still significantly higher than pre-pandemic levels. Nearly 1 in 3 students in North Carolina were chronically absent in 2021-2022[3]. This is a serious crisis that threatens the success of our students and our state, as well as our recovery from the learning losses caused by the COVID-19 pandemic.
The intent of this legislation was to understand how student attendance was impacted by COVID-19 and remote learning, as well as to identify strategies and policies that could be implemented to support students in returning to school.
However, OSA went far afield from the scope given by the General Assembly, and early conversations with OSA revealed a lack of understanding of the subject matter and the data required to perform the analysis. OSA not only failed to finish this analysis in a timely manner, but they also produced a report that shows their work was flawed both in concept and in execution.
NCDPI was optimistic that this report would provide the guidance schools desperately need, but instead it provides nothing that schools are able to operationalize to get even a single student back in the classroom. Instead of delivering recommendations that could be useful to the General Assembly, NCDPI, and the districts, OSA wasted $350,000 of COVID-19 relief funding and well over 1,000 hours of NCDPI and public school unit (PSU) staff time producing a report that did not answer the questions posed by the General Assembly.
NCDPI strongly disagrees with the findings of OSA’s report as follows:
- OSA was provided with the data they requested to analyze student attendance records, but did not understand how to use it, even after multiple attempts to explain it from NCDPI and our PSUs. The data requested was also readily available in more usable formats without requiring OSA analysis.
- The delay OSA claims was caused by NCDPI’s alleged mismanagement of the data was caused by OSA’s mismanagement of this analysis.
- OSA claims NCDPI lacked oversight of the Student Information System (SIS) vendor, was unable to verify data provided to auditors, and did not monitor the districts and schools. This is false but is also immaterial given the flaws in their analysis and inaccuracies in their findings.
- Because of their flawed process and conclusions, their recommendations are largely without merit, and their report is without impact.
OSA’s poor methodology and lack of understanding of the subject matter is further explained in the following descriptions of what was wrong with the efforts of OSA.
Methodology
OSA goals. The goals identified by OSA’s report address the following:
- Whether the six public school districts complied with the North Carolina Compulsory Attendance (Truancy) Law during the 2020-2021 school year. Specifically, did schools perform the actions required for students with three, six, and ten or more unexcused absences. If not, determine the cause and impact.
- How many students attending schools within the six public school districts were chronically absent during the 2020-2021 school year.
- How many students attending schools within the six public school districts that were chronically absent during the 2020-2021 school year were promoted to the next grade level or graduated.
- Whether the six public school districts ensured that student attendance data for the 2020-2021 school year was complete and accurate. If not, determine the cause and impact.
NCDPI contends that these goals, if fully executed, do not approach the directive “to perform detailed analyses of the attendance and truancy policies and procedures for the 2021-2022 school year.” While statute gives OSA the authority to look at any aspect of state government, it still must fulfill the requests of the legislature.
OSA request for attendance data. In November of 2021, NCDPI was approached by OSA with a request for data on school attendance numbers for the purpose of conducting this review. OSA asked for the individual attendance records per student per class period for the six districts (at least half a million records per school day) to recreate student attendance calculations that exist within the SIS. Calculating summary attendance from individual records is complex and requires a deep understanding of attendance policies, both at the state and district level. NCDPI was never in-scope for this review nor was an engagement letter ever sent to NCDPI.
Attendance summary records already existed within the SIS – this data was offered to OSA and refused until November 2022. Over the course of nearly a year and a half, OSA came back with repeated changes in their requests -- from changing the scope to adding additional data fields -- recreating student attendance records that already existed and were already validated within the SIS. While there were human errors in some of the data sets provided, they were quickly corrected, typically within 48 hours depending on the size of the request. Throughout this process, both NCDPI and the PSUs appealed to OSA staff to change their approach to yield more useful results, but these requests were repeatedly ignored. NCDPI and PSU staff also stated repeatedly that the data and information they were seeking could be much easier obtained and validated from the individual PSUs rather than from NCDPI.
The PSU has direct access to its attendance data. They could provide the same datasets more easily than NCDPI, while also providing context to explain variances in the data relative to the way the district operationalized their attendance policies during COVID-19. NCDPI also encouraged OSA to utilize a sampling of the data instead of the entire data set. Curiously, this request was refused by OSA even though they used sampling to draw refutable conclusions in their report. NCDPI attempted to reconcile the findings from OSA’s report using the data files shared. Through this effort, NCDPI staff have identified several flaws within OSA's analysis of the data including the inclusion of pre-Kindergarten students in some calculations, which significantly skewed the numbers provided.
In addition to being able to get more complete attendance data from PSUs, much of the data OSA was attempting to recreate, including chronic absenteeism, was available publicly within the School Report Card[4] with data sets available for researchers[5]. However, NCDPI maintains that these data sources were unnecessary to meet the purpose of this report.
Attendance policies. PSUs have considerable flexibility to enact attendance policies. State law defines truancy, charges the State Board of Education with defining attendance and excused absences, and requires attendance to be taken. However, districts have considerable local control when defining how attendance policies are enacted in the school, and NCDPI and the State Board of Education have limited oversight of attendance. Schools may take attendance once per day or in each class period depending on the school structure and schedule. Elementary schools typically take attendance daily, whereas high schools typically take attendance per class period. Class period attendance is converted to daily attendance for reporting purposes.
During COVID-19, schools changed their policies to provide additional flexibility for determining if a student was marked present or absent. A student may have been marked present even if he/she were off-camera and didn’t speak during class, if he/she turned in an assignment. The calculation of attendance was changed to match the ways students interacted with their school and their teachers. There was also significant variability between districts and within districts about how this was operationalized based on the unique circumstances within each school, district, and community.
During the pandemic, many of our students faced challenges that they had never experienced before. Many were caring for or lost[6] members of their family, and some students became the primary breadwinners in their families as COVID layoffs began[7]. Some students experienced food insecurity for the first time. In 2020, approximately 30% of households in the state did not have broadband Internet access, and only 37% of households with incomes less than $20,000 had Internet access[8].
To address this, PSUs scrambled to purchase computers, while using school buses[9], parking lots[10], and public Wi-Fi to keep students connected and engaged and in school. School buses carried assignments, meals, and resources to many of our communities. The Ocracoke School in Hyde County was forced to try to navigate the COVID-19 pandemic one year after their building and much of their community was destroyed by Hurricane Dorian[11]. In support of our students, schools changed their attendance policies to ensure that they could meet the needs of their students – physically, emotionally, and academically. The way this manifested in attendance data looks different in every district based on the needs of that particular community[12]. In response to these needs, NCDPI and the State Board of Education adjusted student attendance policies to provide the flexibility requested by our LEAs within existing laws[13]. However, because there was unprecedented variability in the way schools recorded attendance at the time, the attendance data does not accurately reflect the policies that were being implemented at the district level, nor do they capture the way that students who were chronically absent were supported.
The extent to which schools were able to follow pre-COVID truancy laws is tangential to the request made by the General Assembly to understand the impacts of COVID-19 on student attendance policies and procedures. Moreover, the recommendations that we were hoping to receive from the Auditor’s Office could have been invaluable to help schools and state leaders recover from the pandemic.
Finally, the OSA report indicates that the PSUs failed to follow the statutory notification policies for students who have three, six, or ten unexcused absences. While technicalities within the law may not have fully operationalized during the pandemic, this report is unnecessarily critical of these districts whose staff went well above and beyond to locate students, get them in school, follow truancy laws with compassion, and support the needs of the whole child[14] to ensure continuity in their education.
PSU Nomenclature
Chronic absenteeism vs. truancy. In addition to truancy, OSA chose to look at chronic absenteeism and the number of chronically absent students who were promoted or retained at the end of the school year. There is a fundamental difference between chronic absenteeism and truancy. A student is chronically absent if they miss more than 10% of their instructional year (typically 18 days). Chronic absenteeism includes all absences, including unexcused and excused absences. Truancy only includes unexcused absences. Given that students were required to be out of school for ten days after a COVID exposure, combined with other challenges of the pandemic, it is unfortunate but understandable that the number of chronically absent students doubled from 2018-2019 to 2021-2022[15]. Consider a student who had to stay home due to two COVID exposures in the 2020-2021 school year. This student may be considered chronically absent but may also be keeping up with all their schoolwork and maintaining academically. For these reasons, a correlation between chronic absenteeism and promotion status cannot be inferred.
Attendance vs. membership. The OSA report details the potential impact on school funding based on attendance and chronic absenteeism. This suggests a lack of understanding about how schools are funded and the relationship between membership and attendance.
Unlike many other states, North Carolina’s school funding model funds schools based on the average number of students in membership, not in attendance.
Membership is determined by the number of students who are enrolled in a school at any given time. Attendance is defined as the number of students who are present or absent on any given day. A student who is absent is still in membership at the PSU and remains in membership unless they are absent for 10 or more consecutive days with unexcused absences. For Local Education Agencies, funding is complex -- initial funding is based on the higher of the prior year actuals and the current year projections. Adjustments to actual are only made if the differential is more than 2% or 100 students and only applied to 50% of the difference in the number of students and only to 75% of the funding categories. A student is in membership the first day the teacher counts them present and remains in membership until a student withdraws. During COVID-19, flexibility was added that a student may be counted in membership during remote learning if a two-way communication occurred between the teacher and the student.
There is always a difference between the average daily attendance within a PSU and the average daily membership within the PSU. NCDPI produces a report comparing both values and posts them to the NCDPI website[16] each year. This is provided to help identify the average attendance rates in schools but these two data points are otherwise unrelated.
Therefore, OSA’s recommendations concerning school funding are refuted because attendance policies are typically unrelated to school funding. OSA’s lack of understanding of these policies and the relationship between membership and attendance contributed to the problems with this report.
Student Information System
Findings within the OSA report claim there are problems with the SIS and lack of NCDPI oversight of the vendor. We have a team at NCDPI who manages the SIS and provides significant oversight of the vendor, communicating with them daily.
North Carolina has used a statewide student information system (SIS) for the past 40 years through several different vendors. This statewide approach supports consistency and increased timeliness in reporting while allowing for greater efficiency, cost savings, and scalability over each PSU procuring their own platform. While the SIS is owned and managed by NCDPI, NCDPI has limited statutory and policy authority over the attendance data that PSUs choose to input into the SIS and the way they configure attendance and scheduling policies within the SIS. PSUs have autonomy over bell schedules, attendance reporting, and determining if an absence is excused or unexcused based on State Board of Education policy. NCDPI provides technical assistance and structural support to the PSUs as needed, while allowing the experts closest to the schools who know best how the system needs to be configured to make those decisions for effective school operations.
NCDPI has been directed by SL2016-94 to modernize the SIS and this work is already well underway. When the transition to the current SIS occurred in 2013, several design decisions were made including customization of the system and data systems requiring vendor involvement to pull large amounts of data out of the SIS. OSA shared outdated news reports in an attempt to suggest that NCDPI is not managing the SIS vendor and that the data within the SIS are inaccurate. The examples shared are related to the initial implementation of the SIS and are long since resolved. The data in the SIS is validated frequently by students, teachers, administrators, and parents.
Impact
Instead of producing a report providing usable recommendations to schools, NCDPI, and the General Assembly, OSA engaged six PSUs and NCDPI in a years-long runaround chasing data that was not relevant to the policies and COVID-19 impacts they were charged with analyzing. It is unfortunate that six of our PSUs are being publicly chastised for prioritizing student well-being during the COVID-19 pandemic. These PSUs have been required to waste significant time and resources producing reports and explaining data to OSA. This time could have been spent supporting their students. This untimely report is a missed opportunity to provide meaningful feedback on attendance policies and has robbed our PSUs of an opportunity to adjust their policies during the COVID-19 pandemic.
[4] https://ncreports.ondemand.sas.com/src/
[5] https://www.NCDPI.nc.gov/data-reports/school-report-cards/school-report-card-resources-researchers
[6] https://www.cdc.gov/media/releases/2021/p1007-covid-19-orphaned-children.html
[9] https://www.ednc.org/school-buses-to-serve-as-wi-fi-hot-spots-for-remote-learning/
[10] https://www.nytimes.com/2020/05/05/technology/parking-lots-wifi-coronavirus.html
[11] https://www.ednc.org/from-dorian-to-covid-19-hyde-county-schools-meets-disruption-with-resilience/
[12] https://bestnc.org/spotlight_on_enrollment_and_attendance_during_covid-19_pandemic/
[13] https://www.newsobserver.com/news/local/education/article255551316.html
[14] https://www.ednc.org/inside-one-districts-efforts-to-feed-all-students-during-covid-19/
[15] https://www.newsobserver.com/news/local/education/article278105172.html
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