For the upcoming year, school leaders across the state are trying to plan ahead for how they will handle remote learning in the event of a health-related closure. This includes planning for how to count students and take attendance during a remote learning period. A little over a week ago, MDE released a pair of memos (linked below) that outline the current options available to schools for pupil accounting in the event remote learning becomes necessary. While these memos do not address every possible circumstance and you will likely still have questions (we know we still do), they are still a must read for Principals and other school leaders.
To help you wrap your head around them, we've outlined our key takeaways below. Please know, also, that MASSP is continuing to communicate with the Department and the Legislature on these issues and to pursue additional relief and flexibility for districts. Please feel free to share your questions and concerns with us and we will continue to pursue answers.
- The biggest change outlined in this memo seems to be that districts may now use the pupil accounting rules under section 21f and 5-O-D of the Pupil Accounting Manual to accommodate remote learning in response to a quarantine, school closure, or similar situation. This is a big departure from our understanding of what the rules previously were and we are pursuing clarification to be sure our interpretation is accurate. MASSP's understanding previously was that virtual learning under section 21f required that primary course content for all virtual learning courses to be accessible via a digital learning environment. This memo indicates that districts could deliver course content exclusively in-person and then transition students to virtual, asynchronous content and back provided that they have met the requirements for virtual learning under 21f.
- The requirements for 21f are identical to the way they were pre-pandemic. All of the provisions that were waived last school year are back in force. In particular, if you want to pivot to virtual learning you need to (among other things):
- Have documented parent consent for all students participating in virtual learning.
- Have an EDP on file for All students participating in virtual learning (EDPs do not need to be completed by Count Day, but must at least be started).
- Ensure all courses being taught virtually are listed in the school's course catalogue. MDE has told us verbally that if you are transitioning your in-person courses to virtual and already have those courses listed in the catalogue, that counts.
- Have properly credential staff assigned as a teacher of record for each course.
- The pupil accounting requirements for virtual students are also back to the way they were pre-pandemic. Some of the rules schools are familiar with from last year no longer apply. Some are less restrictive, some are more restrictive, some are both. Make sure you review section 5-O-D of the Pupil Accounting Manual (PAM) and be familiar with the requirements for counting those pupils in membership.
- Completion of an assignment CANNOT be used to satisfy the two-way interaction requirement for virtual instruction. However, discussion of a completed assignment CAN be used to satisfy the two-way interaction requirement. Be sure to check with your local pupil accounting auditor and have a common definition of what this means. Based on our discussions with MDE, a teacher providing students with written feedback on a completed assignment should count as a two-way interaction, but verify this with your local pupil accounting auditor before relying on it.
- Fully virtual students are NOT included in the 75 percent attendance requirement calculation. These students are not bound to an attendance requirement and would not be included in the districtwide calculation of attendance.
- Districts need to ensure that the teacher of record for all of their virtual courses is properly endorsed in both grade-level and subject area. This requirement may be new to you. The penalties related to it were waived last school year and we are working to get them waived again this year (we already got half of them waived in the K-12 budget), but they haven't been fully waived yet. So please double check your teacher placements to ensure you are avoiding problems,
Still have questions? So do we. We're working with MDE on answers for how to handle students who need an option for offline remote learning. We are speaking to the Legislature about waiving requirements like EDPs and parent permission. We're looking into ways districts can schedule remote learning ahead of time to accommodate things like state assessment days. And we are pursuing additional flexibility for schools moving forward beyond the 2021-22 school year.
As always, MASSP will follow up with members as we get more information.