Understanding FY18 EMIS Withdrawal Scenarios and Best Practices

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Presented by Theresa Reid, this session covers the importance of accurate EMIS reporting for student FTE calculation and funding. It discusses withdrawal codes, dates, scenarios, challenges, and the impact on accountability measures. Knowing the rules from federal and state laws is crucial to avoid negative financial consequences and ensure compliance with regulations.

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FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION FRIDAY, JANUARY 26, 2018 Presented by Theresa Reid EMIS Support Liaison

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION Disclaimer: This information included today was provided by and/or set forth by ODE EMIS. This presentation is not intended to cover requirements of the Missing Children s Act or any other Federal or Legal Situations. Each district needs to determine their own practices as to how data is reported, including withdrawals.

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION Agenda Why the constant reminders? Knowing the rules Finding the rules Priority of rules Withdrawal codes Withdrawal dates Scenarios and Best Practices Challenges and Roadblocks

WHY THE CONSTANT DISCUSSION AROUND WITHDRAWALS? ODE still seeing inaccurate EMIS reporting Withdrawals directly impact the student FTE FTE calculation Enrolled hours x Percent of time _____________________________________________= Student FTE Calendar hours Incorrect withdrawals can cause a negative FTE adjustment (loss of funds) Can also cause overlapping dates (loss of funds) Update your calendars with any calamity days (impacts funding)

WHY THE CONSTANT DISCUSSION AROUND WITHDRAWALS? Inaccurate withdrawals also impact Accountability measures Graduation Cohort Full Academic Year Assessments WKC Reporting withdrawals incorrectly can also generate findings in an FTE audit Documentation has to be present and supportive of the reporting

KNOWING THE RULES Where are the Rules? Federal and State Laws ESSA (Every Student Succeeds Act) House Bill 410 Truancy Laws Missing Children Act Ohio Revised Code Ohio Attendance and Tuition Guide (OSBA) Compulsory Education policy EMIS Manual Section 1.1 EMIS Overview Section 2.1.1 Student Enrollment Overview Section 2.4 Student Standing Record (FS) Local Policies

KNOWING THE RULES Hierarchy of the Rules Federal Law State Law ODE Policy Local/District Policy Local policy can refine and supplement higher policy, but cannot override it Local policy does not supersede higher policy!

KNOWING THE RULES ORC 3313.672 alsospells out the documentation that is required by state law for a child to be enrolled in a district.

KNOWING THE RULES ORC3313.672 (A)(4) - Withdrawals and Records request Within 24 hours of a student s entry to school, a request for records from their previous school must be made. If neither the previous school records nor a birth certificate (or other acceptable documentation per above) is forthcoming within 14 days, or if the previous school reports having no record of the student s attendance, then the principal must report to local law enforcement where the child lives and that the student may be a missing child. Note: Entry in this context means the start of a student s attendance. If, for example, a student is enrolled in July and school doesn t start until September, the 24 hour deadline is after the student first attends the district in September. Also referenced in 2.1.1 Student Enrollment Overview v4.0 page 9

KNOWING THE RULES Districts must maintain documentation to support any withdrawal code reported for a student. ORC 3317.031defines information that must be maintained in student s membership record , including information on enrollment, withdrawal dates and days absent.

KNOWING THE RULES ORC 3313.031 institutes that records retention policies must ensure these records be maintained for five years after the student has exited the district. Districts may not have policies for purging records before that time. Also referenced in 2.1.1 page 2 of the EMIS Manual

KNOWING THE RULES EMIS and other Federal, State, and/or Local laws may have different requirements, in terms of actions, documentation, and timelines. In some cases where a student has been withdrawn from school, the district s responsibility to that student does not end. For example, if a student is withdrawn, is still of compulsory school age, and is not enrolled anywhere else, the district must still conform to local and state policies, rules, and laws concerning truancy. As part of this, districts still have documentation requirements, such as the continued tracking of absences and the maintenance of records documenting the steps taken in fulfillment of such policies, rules, and laws. Once a student is reported to EMIS as withdrawn due to truancy; attendance would not be reported for dates after the withdrawal date. However, the district s responsibility to that student does not end. The district must still maintain and document an accurate count of absences.

WITHDRAWAL CODES Use the withdrawal code that most closely defines the situation Report the code that you are able to document EMIS Manual 2.1.1 Student Enrollment Overview Table on page 4 defines necessary documentation The Preferred Documentation ODE favored documentation that should be maintained in student files to support the withdrawal code (Priority documentation) Other documentation In instances where districts are unable to secure the Preferred Documents listed, other documentation would be acceptable alternatives to support the withdrawal code If neither option; Preferred or Other, is an option, use caution and good faith documentation

WITHDRAWAL CODES Withdrawal Table (sample) from 2.1.1 Student Enrollment Overview of the EMIS Manual (Documentation Rules) EMIS withdrawal codes are all listed in section 2.4 Student Standing (FS) record of the EMIS Manual (Codes)

WITHDRAWAL CODES Generally, a document from another party (e.g., a parent, another district, court system, etc.) is required for a withdrawal. If nothing is received from a responsible party, then documentation of the steps taken and information gathered by district staff must be on file. If an ODE system (ODDEX History or SOES for example) shows that the student has enrolled in another district, a screen print along with documentation of confirmation of admission from the other district can be maintained in the student file to document the withdrawal. In situations when a student is shared between districts (e.g., JVSD students, court-placed students, etc.), it is not required that both districts maintain copies of all relevant documents. The districts involved should work together to ensure that relevant documentation exists, and the district that is not maintaining copies should document in the student s file that the district is relying on the documentation maintained by the other district. 2.1.1 Student Enrollment Overview Page 2, 3 It is important to understand that withdrawal data and documentation is subject to audit.

WITHDRAWAL CODES Withdrawal Code 35 Withdrew from Educating entity, Resident district no longer responsible Example: Student open-enrolled from District of Residence (A) in to District B, moves to and enrolls in District C District A withdraws using 35, withdrawn to IRN ****** District B withdraws to District C (41 code, withdrawn to IRN of C) District C enrolls with Admitted From IRN of District B Withdrawal code 35 may only be used by the Resident district and only when reporting a district relationship of 3 May not be used by resident district when the educating district withdraws the student using 43, 45, 48 or 71-81. Additionally, may not be used by resident district when Sent To is AU, CE, CR, CT, FP, JP, JV, MR, OS, PI or PP.

WITHDRAWAL CODES Withdrawal Code 81 Student reported in error and should have never been reported Withdrawal date should be the same as the enrollment date (or point that they shouldn t have been reported) Document the nature of the situation that supports the withdrawal Example: Student was reported as wd in the prior year Withdrawal code 79 Student is no longer eligible to be enrolled Document the nature of the situation that supports the withdrawal Example: OE Denied, Falsification of residency, etc. If the only documentation the district has indicates the student is not eligible to attend in the district (OE denied, for example) and there is no documentation to indicate where the student will be attending, then 79 is appropriate. If the district has documentation indicating where the student will continue their education, then the 79 would not be appropriate.

WITHDRAWAL CODES Withdrawal Code 71 withdrawal due to truancy Requires a significant amount of supporting documentation. All steps taken by the district must be documented The student s absences must be accurate and complete Documentation must continue beyond the withdrawal of the student ONLY used when the student has been declared truant by the court and must have supporting court documentation Regarding HB410 (per Office of School Improvement) In general, districts cannot file truancy charges until the student has had 60 days on an absence intervention plan The school official would file on the 61st day if the absence intervention team determines the student did NOT make progress on the plan. *However, if the student misses 30 consecutive hours or 42 hours in a month without legitimate excuse during the 60 day intervention plan, the attendance team can direct the school official to file for truancy before the 60 day period is over.

WITHDRAWAL DATES Reminders: A withdrawal date is at the end of the day A withdrawal date indicates that the student was enrolled that day An admission date is at the start of the day Admission date for newly enrolled student is their first day of attendance

WITHDRAWAL DATES The withdrawal date should be supported by the documentation on file If a signed form is given in advance of the student s last day, the withdrawal date should be the date indicated on the form If a signed form is not given in advance, the withdrawal date would be the date of the receipt of the notice If neither of these are on file, then use the most appropriate, documented, date;date of death, medical withdrawal, etc. A summer withdrawal is after your last day of school and before the first calendar start date of the district in the next school year Summer dates do not necessarily have to match the date of the summer withdrawal

WITHDRAWAL DATES Districts should NOT report absences to EMIS for dates after the student has been withdrawn This practice is not acceptable and can generate a finding or other penalty Summer withdrawal dates do not have to match the date of the withdrawal Note: ODE is performing audits on live data, no longer just prior data.

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION ** After the break, we will look at a few scenarios .

WITHDRAWAL SCENARIOS eSchool Withdrawal Student withdrew to an online community school and you received a request for records Student never logs in at the eSchool, so eSchool never reports the student to EMIS Ideally district would have noticed that the student never actually enrolled at the other entity (or any other entity) and would have pursued attendance/truancy/laws. The original withdrawal should remain

WITHDRAWAL SCENARIOS Student in Prison Students sent to adult PRISON (not a local or county jail) are reported with the most appropriate withdrawal code Report the most appropriate code and report it consistently Ohio DRC (Department of Rehabilitation and Corrections) operates a school for students sent to prison, but they do not report to EMIS. ODE is still working with legal to provide EMIS reporting instructions.

WITHDRAWAL SCENARIOS Student in Jail Students sent to adult JAIL are not to be simply withdrawn (example county or local jail) regardless of whether they are special ed or regular ed Assuming they have not completed their education, and there is no other withdrawal documentation on file, they are still entitled to said education and would be marked absent until there is a documented reason to withdraw. The resident district and the district in which the jail resides (if different) should work with the jail to see that he is educated. If this is a special education student, then the district should contact the Office for Exceptional Children for details on what education/services must be provided.

WITHDRAWAL SCENARIOS Student left the country unable to return If a student is out of the country for a period of time, the student should not be withdrawn and then re-enrolled upon returning. If the student has received an excuse for the absence, the student is re- ported as any other student with an excused absence. If the student has not received an excuse for the absence, the district must document its efforts to attempt to ascertain the location of the student and when the student is expected to return. If the district is unable to ascertain information concerning whether or when the student will re-turn, the district must follow the appropriate attendance and truancy laws and policies and may withdraw the student accordingly. If the district has documentation that the family no longer resides at its previous residence or anywhere within the district, the district may withdraw the student with the most appropriate withdrawal code. Per 2.1.1 of the Manual, page 18

WITHDRAWAL SCENARIOS Student left the country unable to return Example: Student travelled over the summer to their country of origin Family is not permitted back due to a travel ban, expired passport, etc. Family intends to return, when permitted Per ODE: District does not have proper documentation to support a withdrawal Since the family intends to return and is not enrolled elsewhere, 46 (out of country) is not appropriate You should mark the student absent (excused or unexcused is up to district policy) and follow local attendance and truancy laws and may withdraw the student accordingly.

WITHDRAWAL SCENARIOS Foreign Exchange Students When foreign exchange students complete their program and leave the district in order to return home, they are reported with a withdrawal code of 46 -Transferred out of the United States. For resident students leaving the district as foreign exchange students, whether they are withdrawn from the district depends on the situation. Students engaged in educational options that belong to the resident district, for instance, would not be withdrawn. If the foreign exchange student is not receiving any education or services from the resident district, then he or she is withdrawn with the most appropriate withdrawal code. 2.1.1 of the Manual, page 17

WITHDRAWAL SCENARIOS Students over 18 year of age The withdrawal process must be initiated by the student or parent Signed withdrawal form along with proof of students age (i.e., birth certificate) The fact that the student is 18 does not relieve the district of its responsibility to follow up with the student and properly document the withdrawal As long as student has not met graduation requirements, district must follow appropriate attendance policies (Compulsory Education) 2.1.1 of the Manual, page 29

WITHDRAWAL SCENARIOS Withdrawal and enrollment How long does a student have to enroll in the new school? There is no set timeframe in law Scenario: A student is formally withdrawn from the district by the parent Student should be withdrawn and reported to EMIS as withdrawn The withdrawing school watches for the records request Records request is received and student begins attending at other school

WITHDRAWAL SCENARIOS Withdrawal and enrollment, continued Same Scenario: A student is formally withdrawn from the district by the parent District does NOT withdraw the student and reports absences until the student enrolls at the new school and a records request is received Once the request for records is received, the district then withdraws the student using the original date on the withdrawal form and removes absences that were entered after that date. This scenario does not follow EMIS protocol and would not acceptable in a audit situation SCR reporting will not be correct until the withdrawal is reported. Causes unfounded SCR errors and FTE adjustments that can affect other entities

WITHDRAWAL SCENARIOS Are there other scenarios that you would like to discuss?

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION Challenges and Roadblocks Parents Do not wd their student Uncooperative in providing details Don t know where they are going Do not enroll in a timely manner at the new school Other Districts Uncooperative in sharing details Delayed request for records Delayed EMIS reporting

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION Challenges and Roadblocks, continued.. Your own district Untimely withdrawals in the system Inadequate supporting documentation Not enough information for a withdrawal Inadequate record keeping (filing system, etc.) of supporting documentation Untimely EMIS reporting Inconsistency in withdrawal processes among individuals and/or buildings Inconsistency on follow up on students once they withdraw Changes to EMIS reporting requirements around withdrawals

FY18 EMIS WITHDRAWAL SCENARIOS AND DISCUSSION Our SWOCA challenge Are there other challenges that you face in your district?

PROCESSES AND PROCEDURES Review your internal workflow Who withdraws your students? Paperwork EMIS withdrawals Who withdraws students that attend elsewhere? How do you notify other schools when a student you are educating withdraws from your district? JDC, Scholarship, etc. How do you follow through on withdrawn students? Request for records Enrollment in new school (any school)? Is your withdrawal form complete enough? Does it allow for all the necessary documentation?