Electronic Attendance Accounting

August 3, 2009

Dear County and District Superintendents, and County and District Chief Business Officials:

NOTICE OF ELECTRONIC ATTENDANCE ACCOUNTING AND TEACHER SIGNATURE ALTERNATIVES

In February 2008, the California Department of Education (CDE) notified all county and district superintendents of the intent of the CDE to allow such local educational agencies (LEAs) to replace manual teacher signatures with digital signatures or other electronic certification processes. The CDE was to develop parameters for a pilot program that would be available beginning in school year 2009–10.

The CDE has completed its review and believes the parameters, as described below, are sufficient to forego the pilot concept. Any LEA may now seek approval by CDE of an electronic certification process that adheres to the parameters.

In accordance with California Education Code Section 44809 and California Code of Regulations, Title 5, Section 401, the CDE is required to approve the forms and procedures that constitute LEAs attendance accounting systems. Currently, the CDE approves attendance accounting systems in which teachers manually sign and date attendance registers, depending on the type of attendance accounting system used. For online attendance accounting systems, approval is given to systems that provide for teachers signing and dating a weekly printout of attendance records entered online during the previous week.

Beginning with the 2009–10 school year, CDE approval of attendance accounting systems containing digital teacher signatures must minimally contain all the following characteristics:

1. A current system with manual signatures has been approved by the CDE;
2. The electronic system has a procedure to track and verify that initial attendance is entered on the calendar day of the school day for which the attendance is a record thereof. Under certain circumstances, such as wide-spread power outages or system interruptions teachers may be allowed to electronically submit and certify attendance on a subsequent day, retaining paper documentation on which attendance was recorded contemporaneously;
3. The electronic system includes a report that lists the dates of data entry and modifications, and the employee identification of the person or persons logging the attendance information into the system;
4. The report described in #3 above is readily accessible to teachers and administrators for their review;
5. If the electronic system relies on passwords, there must be adequate safeguards to ensure that such passwords are accessible only to the employee for whom the password is created; and
6. Submission of the electronic attendance system for CDE approval includes a letter from the LEA’s independent auditor, indicating that the attendance accounting system has been reviewed by the auditor and that the system’s level of integrity is acceptable to the auditor.

Please send requests for approval of attendance accounting system electronic certification to: 

Kim Clement, Education Fiscal Services Consultant
[Note: the preceding contact information is no longer valid and has been replaced by Categorical Allocations and Audit Resolutions Office. Please contact them by email at attendancerequests@cde.ca.gov.]

Important to note is that LEAs remain responsible for the integrity of the attendance information. It is this attendance information that is the basis for LEAs funding. It is the intent of CDE, consistent with past practice, not to approve a J-13A, Request for Allowance of Attendance Due to Lost Records waiver for the failure of an electronic attendance system.

If you have any questions regarding this subject, please contact Kim Clement, Education Fiscal Services Consultant, School Fiscal Services Division, at 916-327-0857 or by e-mail at kclement@cde.ca.gov [Note: the preceding contact information is no longer valid and has been replaced by Categorical Allocations and Audit Resolutions Office. Please contact them by email at attendancerequests@cde.ca.gov.].

Sincerely,

JACK O’CONNELL