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Guidance on Enrollment of Students During the Physical Closure of Schools
Goals:
- Ensure educational services are provided to all students through the end of the 2019-20 school year and its extended closure.
- Ensure school funding is stable and based on reliable and accessible data for all public schools.
- Provide clear, consistent guidance for public schools.
Background:
Governor Brown’s Executive Order 20-08 physically closed all public schools but required schools to operate in a specific capacity by providing Distance Learning for All and other essential services. The Oregon Department of Education (ODE) provided guidance that virtual charter schools could not enroll students after March 27, 2020. This directive was made to account for the state’s inability to accurately adjust enrollment across and between schools during the closure.
This directive on virtual public charter schools raised questions relating to whether all public schools can enroll students during the closure and whether a student can withdraw from a virtual public charter school or other public school. School districts must enroll and serve students within their district boundaries.
At this time ODE and school districts do not have accurate data to drop student enrollment after a period of absence; this is a fundamental aspect of our school funding allocation system. Schools have been providing a range of services under E.O. 20-08 and beginning April 13, all public schools will be implementing a plan to provide distance learning for all students. Many schools are not yet able to reach all their students and some may not be able to locate all students going forward. Students should not be dropped from enrollment under this circumstance, as not all students may be readily located and served during this crisis and districts must continue to seek them out and provide services. Also, dropping students in this situation has the potential to destabilize the state school fund allocation model, making budgeting and planning unpredictable for school districts.
While there may be no perfect solution in this challenging time, this is an approach that will allow us to achieve our goals:
- For the remainder of the 2019-20 school year, ADMw for all public schools will be based on 2nd period data (December) and then will be reconciled in the May 2021 payment which is normal practice.
- The next State School Fund (SSF) reconciliation in May of 2021 will continue to use the 2019-20 2nd period ADM in its final reconciliation. This would include the ADM associated with General Education, English Language Learners and Pregnant and Parenting. ADM reporting for the 2020-21 SSF would follow normal procedures until further notice.
- ADMw is not being adjusted by the enrollment or withdrawal of students during this closure period.
Guidance:
Our school funding system is based on students being enrolled and served in our schools. At this time schools are attempting to reach all students, but may not be able to reach all families. Yet, the state will provide funding as if school was actually in session.
Our enrollment system that tracks Cumulative ADM will not have all the data it needs to function appropriately in our current circumstance. This is why virtual public charter schools were initially stopped from enrolling additional students. ODE cannot shift funding based on some known student transitions while unknown transitions are not recorded, as the student accounting will not balance and the allocation model will become unstable. Under the current situation, the statewide system cannot accurately adjust ADM from one entity to another.
School districts must enroll and serve resident students that arrive in their boundaries or transfer through other acceptable processes. Public charter schools, including virtual public charter schools, may enroll students based on their policies, charter agreements and state law. As ADMw will not fluctuate during this period, virtual public charter schools and other public charter schools should consider working with their sponsoring district to cap their enrollment so that they do not enroll beyond their staffing capacity.
Stabilizing enrollment to the degree possible is an important function of this guidance. The more stable enrollment and its associated ADMw can remain, relates directly to how fair and equitable the distribution of the state school fund under the physical closure will be. For this reason it is important that all districts adhere to statute:
339.127 Factors prohibited from consideration when giving consent to nonresident student; limitations on consent and advertisements.
(9)(a) A school district that provides consent to nonresident students to attend the schools of the school district may not expend moneys received from the State School Fund or as Local Revenues, as described in ORS 327.011, to advertise openings for nonresident students if the advertisements are:
(A) Located outside the boundaries of the school district, including advertisements that are made by signage or billboards; or
(B) Directed to nonresident students, including:
(i) Advertisements that are targeted to nonresident students through direct mail or online marketing;
(ii) Television or radio advertisements; or
(iii) Newspaper advertisements, unless the advertisement is in a newspaper that primarily serves the residents of the school district.
339.122 Disclosures in promotional materials.
(2) In any advertising or other promotional materials of a virtual public school, including a virtual public charter school as defined in ORS 338.005, the school must clearly state that the school is a publicly funded school.
338.125 Student enrollment; nonresident students; appeals; written notices.
(4)(a) A student who wishes to enroll in a virtual public charter school does not need the approval of the school district where the student is a resident before the student enrolls in the virtual public charter school. If a student wishes to enroll in a virtual public charter school, the parent, legal guardian or person in parental relationship with the student must provide the following notices to the school district where the student is a resident:
(A) Intent to enroll the student in a virtual public charter school; and
(B) Enrollment of the student in a virtual public charter school.
(b)(A) Notwithstanding paragraph (a) of this subsection and ORS 339.133, if more than three percent of the students who reside in a school district are enrolled in virtual public charter schools that are not sponsored by the school district, a student who is a resident of the school district must receive approval from the school district before enrolling in a virtual public charter school. A school district is not required to give approval if more than three percent of the students who reside in the school district are enrolled in virtual public charter schools that are not sponsored by the school district.
(B) For the purpose of determining whether more than three percent of the students who reside in the school district are enrolled in virtual public charter schools that are not sponsored by the school district, the school district board shall include any students who:
(i) Reside in the school district, regardless of whether the students are considered residents of different school districts as provided by ORS 339.133 (5); and
(ii) Are enrolled in virtual public charter schools that are not sponsored by the school district.
(C) Students who reside in the school district, regardless of whether the students are considered residents of different school districts as provided by ORS 339.133 (5), must receive approval from the school district before enrolling in a virtual public charter school if the limit described in subparagraph (A) of this paragraph has been met.
(c) If the school district does not give approval under paragraph (b) of this subsection, the school district must provide information to the parent, legal guardian or person in parental relationship with the student about the right to appeal the decision to the State Board of Education and other online options available to the student. If an appeal is made to the State Board of Education, the board must issue a decision within 30 days of the submission of the appeal.
(see FAQ for additional guidance)
School districts and public charter schools may not drop students they are not able to reach. However, a parent may choose to withdraw a student from a public school and transfer to another educational option; in which case the receiving district shall enroll the student(s).
Public schools will be funded based on 2nd period Cumulative ADM. Weights used to calculate ADMw for purposes of the State School Fund will be adjusted according to state law. If a school district or charter school enrolls new students or a parent withdraws a student, the public school’s Cumulative ADM used to calculate State School Funds will not be adjusted for the 2019-2020 school year beyond the 2nd period data collection, which closed December 31, 2019.
Frequently Asked Questions:
Q: May school districts enroll students while physically closed?
A: Yes. While closed under E.O. 20-08, school districts must enroll resident students who request enrollment. School districts may choose to enroll non-resident students under current laws such as interdistrict transfers. School districts must provide educational services to all enrolled students pursuant to E.O. 20-08 and the Distance Learning for All students guidance. Public schools will be funded based on 2nd period Cumulative ADM. Weights used to calculate ADMw for purposes of the State School Fund will be adjusted according to state law. If a school district or charter school enrolls new students or a parent withdraws a student, the public school’s Cumulative ADM used to calculate State School Funds will not be adjusted for the 2019-2020 school year beyond the 2nd period data collection, which closed December 31, 2019.
Q: May public charter schools, including virtual public charter schools, enroll students while physically closed?
A: Yes. Public charter schools may choose to enroll students based on their school policies, charter agreements and state law. Public charter schools must provide educational services to all enrolled students pursuant to E.O. 20-08 and the Distance Learning for All guidance. Public schools will be funded based on 2nd period Cumulative ADM. Weights used to calculate ADMw for purposes of the State School Fund will be adjusted according to state law. If a school district or charter school enrolls new students or a parent withdraws a student, the public school’s Cumulative ADM used to calculate State School Funds will not be adjusted for the 2019-2020 school year beyond the 2nd period data collection, which closed December 31, 2019.
Q: Is a public charter school required to continue to enroll students if the public charter school either does not have a cap on enrollment or has not reached its cap?
A: Possibly. If a public charter school has a policy which restricts enrollment beyond its cap such as to a particular date range or a lower cap then the public charter school may deny enrollment based on its policy. If a public charter school has no policy further restricting enrollment and wishes to restrict enrollment then the school may either work with its sponsor to amend its charter to restrict enrollment or adopt a policy to restrict enrollment. Regardless of its policies or charter agreement, a public charter school may not discriminate in enrollment pursuant to ORS 338.125(2)(c).
Q: Does the “3 percent cap” law still apply to virtual public charter school enrollment?
Yes. School districts have the option to deny a student’s enrollment in a virtual charter school if more than 3% of the district’s student population is currently enrolled in virtual charter schools located in other districts. Districts should maintain careful record keeping and provide clear communication with families enrolling in virtual charter schools. When a parent gives the school district notice of intent to enroll a student in a virtual charter school and receives a notice of denial, a parent may appeal the decision of a school district to deny a student’s enrollment at a virtual charter school to the Oregon Department of Education (ODE). For more information on this process see: https://www.oregon.gov/ode/learning-options/schooltypes/charter/Documents/2019%20ode%20virtual%20cs%20enrollment%20appeal.docx
Q: Should districts and public charter schools withdraw a student for attendance (10-day rule) during the extended closure between March 16 and the end of the 2019-2020 school year?
A: No.The “10-day” rule requiring placement of a student on the inactive roll only applies when schools are in regular session days and does not apply during the school closure period as a result of E.O. 20-08.
Q: May a parent withdraw a student from a public school while the school is physically closed?
A: Yes. Although a school may only drop a student from the active enrollment list if the school has received notice from a parent of the withdrawal or the public school has knowledge (e.g. records request or other formal acknowledgement from the other district/school) that the student is receiving services from another school. Students may also be withdrawn if the student is registered with an education service district as a homeschooled student or to enroll in a private school.
Q: Will the enrollment or withdrawal of a student from public school impact the school’s ADM for purposes of the calculation of State School Funds?
A: No. Enrollment or withdrawal of a student will not impact a school district’s or public charter school’s ADMw during the time of school closure. State School Fund allocations for the remainder of the 2019-2020 school year will be based on the school district’s and charter school’s ADM in the 2nd period ADM data collection as of December 31, 2019. The next State School Fund (SSF) reconciliation in May of 2021 will continue to use the 2019-20 2nd period ADM in its final reconciliation. This would include the ADM associated with General Education, English Language Learners and Pregnant and Parenting. ADM reporting for the 2020-21 SSF would follow normal procedures until further notice.
Q: Is a public charter school required to provide educational services to students who are not currently enrolled in the charter school?
A: No. A public charter is only required to provide Distance Learning for All to students who are enrolled in the school.
Q: Should districts and public charter schools code March 16 to the end of the 2019-20 school year as in session and mark students as present in our SIS during the extended closure?
A: During the time school facilities are closed and students are not under the guidance and direction of teachers, per the definition of Day in session per OAR 581-023-0006(f), these days would not be considered a session day. However, schools and districts will still need to track contact with students enrolled at their school(s), to the extent practical, in an attempt to provide distance learning while schools are closed. Per the Executive Order 20-08, schools shall continue to receive allocations from the State School Fund for the period of closure when they meet the five provisions on page 3, Section 4, parts a-e. While there is no expectation that schools track attendance through previously used mechanisms, schools should create a system that logs student contact so they can estimate the number of students engaged during this time, and most importantly, understand which students they are not able to reach through Distance Learning for All. It is important for schools to know which students they need to seek alternative methods to communicate with. This is the key priority for attendance. Accountability related to attendance has been waived for the 2019-20 school year.
Q: I have students from outside my district whose parents have sent them to live with relatives within my district since the March 13th closure. What do I do?
A: Assuming the relative is not a legal guardian or a person in parental relationship to the student, the school district that most recently enrolled the student is still responsible for general education services. You can help by alerting the school district of the student’s new location. If the relative is a legal guardian or a person in parental relationship to the student as defined in ORS 339.133 then you must enroll the student as a resident student upon request and begin serving the student.
Q: Will Annual Cumulative ADM be used for school funding?
A: No, ODE will use 2nd period Cumulative ADM for 2019-20 to determine school funding for the remainder of the school year. The next State School Fund (SSF) reconciliation in May of 2021 will continue to use the 2019-20 2nd period ADM in its final reconciliation. This would include the ADM associated with General Education, English Language Learners and Pregnant and Parenting. ADM reporting for the 2020-21 SSF would follow normal procedures until further notice.
Q: If Annual Cumulative ADM is not used for funding, what will it be used for?
A: Annual Cumulative ADM is the primary source for graduation, completion, and dropout events for our students. School districts must report all graduation and completion events that occurred during the 2019-20 school year and, to the best of their ability, the other outcome events for students enrolled through March 13th, 2020. For the next State School Fund reconciliation in May 2021 ODE will not use the 2019-20 Annual ADM data collection; however, there are still a lot of data in the collection used for other purposes. Therefore, it is very important to complete the Annual ADM collection using the March 13, 2020 cutoff date for these other needs.
Q: What days are considered Session Days?
A: Annual Cumulative ADM session days will include only the session days from the start of the school year through March 13th. The time period when schools are closed, including the period of Distance Learning for All, will not be considered session days for the purposes of ADM.
Q: How do we report days present and days absent?
Days present and days absent are only reported while school is in session. This means that no days present or days absent will be reported in Cumulative ADM during the period of school closure, including the period during which districts are implementing Distance Learning for All. Because March 13 was the last session day in Oregon, days present and days absent would only be reported for the time period from the start of the school year through March 13th.
While no attendance data will be reported for the period when schools are closed, schools and districts will still need to track with students enrolled at their school(s), to the extent practical, in an attempt to provide distance learning while schools are closed, starting April 13th. There is no expectation that schools track attendance through previously used mechanisms. Schools should create a system that logs student contact so they can estimate the number of students engaged during this time, and most importantly, understand which students they are not able to reach through Distance Learning for All. It is important for schools to know which students they need to seek alternative methods to communicate with. This is the key priority for attendance. Accountability related to attendance has been waived for the 2019-20 school year.
Q: How do we report instructional hours for students not in a standard program?
A: For students in a non-standard program (ADMProgram types ‘04’ to ’10’) report the hours of instruction received from the start of the school year through March 13. Do not include any instructional hours for the period that schools are closed by the Governor, including the period where districts are implementing Distance Learning for All.
However, schools and districts must still track the time spent interacting with every student enrolled at their school(s), to the extent practical, in an attempt to provide distance learning while schools are closed, starting April 13th. Additional guidance on this is forthcoming.
Q: Will ODE adjust the Cumulative ADM calculation for those students reported using instructional hours?
A: A school district will receive funding for the second-half of the school year at the same rate it received funding through the 2nd period for students being reported with hours of instruction. The ADM formula for part-time students using hours of instruction takes into account only half of the year, or the state average of 73 days. E.g., Large Group Instruction shall be computed by multiplying total hours of instruction given all students during the reporting period by a factor of .167 and dividing the product by 73 for the July 1 to December 31 period cumulative report. For more information on formulas used for ADM, please refer to OAR 581-023-0006.
Q: We have students who are participating in college coursework during Spring Term and are eligible to do so through the Expanded Options, Post Graduate Scholars, or College Coursework (other) programs to receive Cumulative ADM for these students. How will the Cumulative ADM for these students be reported?
A: For those students eligible for Expanded Options, Post Graduate Scholars and College Coursework (other) you should report the college credits earned during the Spring Term, as applicable. Please only submit records for those students enrolled on March 13.
This applies only to ADM program type codes ‘11’, ‘12’, and ‘16’.
Q: How do we report ADM End Date codes?
A: ADM End Date codes should reflect the status of the student at the time the district ceases to provide Distance Learning for All during the 2019-2020 school year. For example, students who were served for the duration of the Distance Learning for All timeframe and are expected to return to the school in the following school year should be coded as ‘1A’. As another example, students who earn a diploma or other credential on or before June 30, 2020 should have this outcome reported in their End Date Code. This will allow ODE to correctly calculate graduation rates.
Remember that diplomas awarded between July 1, 2020 and August 31, 2020 will be included in 2019-20 cohort graduation rate calculations. They should be reported in First Period 2020-21 with a Program Type 14 record. If a student receives the credential after the end of the district’s period of Distance Learning for All (say June 10) but before June 30, then update the 2019-20 Annual ADM record to indicate that, or make the change during Exit Adjustment in Fall 2020.
We realize that districts may have incomplete information for some students at the time Annual ADM is submitted. Districts should anticipate using the Exit Adjustment window in Fall 2020 to update Annual ADM records, as more information becomes available for their students.
Q: What do we report as the enrollment end date (ADMEndDt) for students already enrolled as of March 13th?
A: Students are still receiving services through Distance Learning for All, even though these days do not count as session days. In order to better understand enrollment, and to receive accurate dates of graduation and other outcome events, the ADMEndDt should reflect either the outcome date for the student or the last day that Distance Learning for All is conducted by the district. (Remembering that the submitted ADMEndDt is the first weekday after the actual event.)
Remember that no session days will be reported while the Distance Learning for All is in operation.
Q: How do we report a student was enrolled on March 13th, but who left the school district during the period of school closure?
A: If a student has enrolled in another district, moved to another state, moved to homeschool or private school, then use the ADMEndDt to record when this student left, and use the appropriate ADM End Date Code.
Q: How do we report a student who enrolled in our district after March 13?
A: In general, you would not report in Cumulative ADM any enrollment for students who were first enrolled after March 13th. However, important exceptions exist.
If a student enrolls in your district after March 13th and has any one of the following outcomes, please submit an ADM program type 14 record for this student:
- Enrolled in another district (2A)
- Enrolled in non-public school or setting, including homeschool (2B)
- Enrolled in another state or country (2C)
- Enrolled in a Public Agency (2D)
- Awarded a High School Diploma (4A)
- Received a certificate of completion (4C)
- Received a GED (4E)
- Met requirements for a high school diploma, but not yet awarded (4F)
- Met requirements for a high school diploma, but continuing as a Post Graduate Scholar (4G)
- Enrolled in a Foreign Exchange Program (5C)
- Died or permanently incapacitated (6A)
- Returned after receiving a credential and exited again (6B)
This information is extremely important and will help ODE calculate accurate graduation rates for 2019-20. These records can be submitted with Annual ADM, or through the Exit Adjustment window in Fall 2020.
Q: We have a student who enrolled in our district after March 13, 2020. We’ve received information that this student has subsequently left the state, enrolled in private school, or the parent has registered the student for homeschool. How do we report this student?
A: It is important for ODE to have information on these events, since we cannot calculate accurate graduation, completion, or dropout rates without it. In these cases, districts will need to submit an ADM record with program type code ‘14’ and the appropriate ADM End Date Code. See the previous question for more details.
Q: Do we need to report Essential Skills information for our graduates this year?
A: No. Essential Skills have been suspended for this year’s seniors, defined as students who first enrolled in ninth grade in the 2016-2017 school year or earlier (including 5th or 6th year seniors), and for students who first enrolled in ninth grade in the 2017-2018 school year or later that have an early graduation plan for 2019-2020 that was approved before the Executive Order (EO 20-08) was issued on March 17, 2020.
Due to this suspension, the Essential Skill fields will allow “0 – Not Applicable” to be used for graduation records. If a student has completed their essential skills you can still provide that information in their graduation record, but you will not receive an error for using “0 – Not Applicable” when completing the records
If you choose to enter an essential skills code, you must submit the corresponding essential skills date.
Q: How do we report the ADMFTE? Our student information system uses a complicated calculation based on required instructional hours. Will required instructional hours be waived?
A: Report ADMFTE based on the FTE of the student’s enrollment through March 13th. Students who were scheduled (while schools were open) in more than one-half of the full-day program are given an FTE of 1.0. Students who were scheduled for one-half or less of the full-day program are given an FTE of 0.5. We realize that this may require adjustments to programming at the local level.
We anticipate that required instructional hours will be waived by the State Board.
Q: What may Transportation Grant Funds be used for under EO-08?
A: Under EO-08, Transportation Grant Funds may be used for:
- Meal delivery
- Transporting children for child care
- Delivering educational materials (including technology and internet access) under Distance Learning for All Students Guidance
- Salaries of school transportation staff
- Costs of contracted transportation services depending on provisions of individual contracts
- Other allowable expenses under state law and rule
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