Local BEdA Reporting and Compliance

Current understanding of requirements relating to collecting Social Security Numbers for the purposes of federal reporting of qualifying tuition and fees for the Hope Tax Credit and the Lifetime Learning Tax Credit:

No reporting is required for courses for which no academic credit is offered. Academic credit is defined as credit for course work leading to a post-secondary degree, certificate or other recognized post-secondary educational credential.

Note: On this basis, reporting is not required for Basic Skills enrollments. Also, non-credit continuing education programs should not be reported.

More information is included in a Nov. 17, 2005 memo sent to college presidents.

Non-Basic Skills ESL students (e.g. college-level, developmental education, international and/or continuing education students) and Basic Education for Adults ESL students (Basic Skills, $25 tuition only) may be in the same classroom if no federal Basic Skills funds are used to support non-Basic Skills students, materials or salaries. Basic Skills ESL students must be registered and coded to a Basic Skills course and Non-Basic Skills students must be registered and coded to a college-level, developmental education, international and/or continuing education course.

Colleges and other providers must account for expenditures related to these mixed classrooms based on the proportionate share of each type of student in the classroom. Please note: only those state funds directly supporting the BEdA students may be used as match for Maintenance of Effort purposes.

Providers must:

• Follow the Assessment Policy.
• Use the state LACES Intake Form or SBCTC-approved form for collecting BEdA student data.
• Follow state policy for recording attendance/contact hours.
• Enter data into the BEdA data collection system – LACES often enough to inform instruction. Data MUST be entered at least quarterly.
• Check local data for errors prior to submitting data to the state system.
• Require that students requesting a tuition waiver sign a waiver form for requesting the waiver and keep that form with the students’ records.
• Have and follow a written progression policy.

Corrections education providers must also:

• Comply with DOC policy.
• Follow Information Standards Board.
• Comply with DOC IT security requirements – college BEdA programs follow campus IT.
• Follow Operational Memoranda of the correctional facility.
• Comply with superintendent of the correctional facility.

SBCTC and its funded providers follow the Washington State Community and Technical College General Retention Schedule for records retention.  Records retention policy specific to Adult Basic Education providers is covered in Section 3.5: Grants Management. For providers offering HS+, additional requirements can be found in the Community & Technical College Retention Schedule Section 5.3 Graduation.

Because the majority of funding for Basic Education for Adults is from federal sources and granted to providers by SBCTC, records retention is covered in record series Disposition Authority Number (DAN) GS 230001, Rev. 1 and reads:

GS 230001, Rev. 1 (General Schedule) Grants issued by the state/SBCTC

Provides a record documenting request for specially funded projects (includes grant announcement and application, notification of grant awards, grant agreement signed by concerned parties, evaluation summaries, fiscal reports, correspondence related to grant monitoring, audit reports and related documentation). Also includes grant project status, data collection and evaluation instruments, questionnaires, statistics and the like, and progress and compliance reports prepared and submitted by grantee.

Office Administering Grant or other Designated Administrative Office 6 Years following:

• Termination of grant
• Resolution of litigation/audits
• Satisfaction of retention period stated in grant, whichever is longest.

Records to be retained include, but are not limited to the following:

• LACES Intake Form (one form each Period of Participation when the student enrolls)
• Attendance (signed original documents with actual number of hours for each day the student participated in a class)
• CASAS pre- and post-test results
• Exception for testing forms
• Documentation of CASAS testing in only one subject
• Registration forms
• Tuition Waivers

Requirements specifically for HS+ read:

20-02-69487, Rev. 0 (CTC Retention Schedule) Graduation Requirements

Provides documentation to support the awarding of degrees, diplomas and certificates of completion. May include copy of graduation application, evaluation of student credits (earned and transferred) and final determination.

WIOA section 116(d)(2) requires Title II providers to report “the average cost per participant of those participants who received career and training services” paid for with federal AEFLA funds. Accordingly, BEdA programs will report Participant counts and AEFLA funds expended on career and training services using the descriptions below and Local Career and Training Services Report Template in WABERS+. Local providers will report data in WABERS+ by the September snapshot each year. Afterward, SBCTC will report statewide aggregate data to the National Reporting System (NRS) on the WIOA Statewide Performance Report by October 1 and Federal Financial Report (FFR) by December 31. It is important for every provider to complete this report, even if no federal funds were expended on these services.

Classifying Career Services and Training Services

OCTAE Program Memo 17-2 classifies career and training services as including the following activities:

Career Services Applicable to AEFLA

• Outreach, intake, and orientation
• Initial assessment (pretest)
• Referrals and coordination with other programs and services
• Provision of performance information and program cost information on eligible providers of education, training, and workforce services by program and type of provider
• Provision of information on availability of supportive services or assistance and appropriate referrals (including child care; child support; medical or child health assistance available through the State’s Medicaid program and CHIP; SNAP benefits; EITC; assistance under TANF, and other supportive services and transportation)

Training Services Applicable to AEFLA

• Training component (the workforce content elements: e.g., welding, NAC, etc.) of Integrated Education and Training (IET) programs (stand-alone IET or part of I-BEST and IELCE programs)

Identifying AEFLA Funds Expended on Career Services and Training Service Costs

WIOA requires that the costs for career and training services be determined separately. Report only funds expended from your BEdA Master Grant and IELCE Grant. Given that WIOA defines “administrative costs” separately from the definitions of career services and training services, do not include administrative costs when reporting costs for career services and costs for training services.

Career Services Costs

• Participants Served – Report the total number of Participants with complete data during the program year (Exclude Reportable Individuals).
• Participants Exited – Report the number of Participants who Exited the program by the end of winter quarter.
• Funds Expended – Report any and only federal dollars spent on the career services identified above.
  • If no federal dollars were spent on the career services identified above, enter zero.

Training Services Cost

• Participants Served – Report the total number of Participants receiving the training component (workforce content elements) of IET programs that are funded by federal dollars during the program year (Include all students in IET/IELCE/I-BEST programs that are funded by federal dollars. Exclude Reportable Individuals).
  • If no participants received the service identified above, enter zero.
• Participants Exited – Report the number of Participants receiving the training component (workforce content elements) of IET programs that are funded by federal dollars who Exited the program by the end of winter quarter (Include all students in IET/IELCE/I-BEST programs that are funded by federal dollars. Exclude Reportable Individuals).
• Funds Expended - Report any and only federal dollars spent on the training component (workforce content elements) of an IET program.
  • If no federal dollars were spent on the training services identified above, enter zero.

A BEdA provider’s performance rates may be significantly understated when student Social Security Numbers (SSN) are not available for matching. Data for several of the mandatory NRS reporting criteria (earning a GED® or high school diploma, getting or retaining employment, and/or enrolling in further education or training are based solely on matching student Social Security numbers with other state agency databases).

All students MUST check "Yes" or "No" when signing the SSN Disclaimer on the bottom of the LACES Intake Form. Only Social Security Numbers for students who check "Yes" are data-matched.

The student, not the BEdA provider, must decide whether to supply a Social Security Number. 

Providers must report and maintain documentation of at least twelve (12) hours from each period of participation and report the last date of attendance for each period of participation. The last date of attendance will be used to calculate program exit if no future services are planned. If a student Exits a program and re-enters again in the same program year, they will start in a new Period of Participation as a Reportable Individual and the program will need to track at least 12 more hours and report another last date of attendance. Reported attendance will be monitored to verify that a Reportable Individual has earned the federally determined minimum number of hours needed to reach Participant status through our program review purposes. Once Participant status is achieved, WIOA outcomes will be tracked.

Contact Hours

Definition. Hours of instruction or instructional activity that the participant receives from the program. Instructional activity includes any program-sponsored activity designed to promote learning in the program curriculum, such as classroom instruction, assessment, tutoring, or participation in a learning lab. Time spent on assessment can be counted only if the assessment is designed to inform placement decisions, assess progress, or inform instruction. Time used simply to administer tests, such as the GED tests, cannot be counted as instructional activity.

Measuring Contact Hours for Participants in Distance Education 

Like all participants, participants in distance education must have at least 12 hours of contact with the program before they can be counted for Federal reporting purposes. Contact hours for distance learners can be a combination of actual contact and contact through telephone, video, teleconference, or online communication, where participant and program staff can interact and through which participant identity is verifiable. In-person contact time is not required to obtain the initial 12 hours of contact.

Contact hours for Basic Education for Adults students include the verifiable hours of instruction or instructional activity the learner receives from the program. Instructional activity includes any face-to-face or contact at a distance using remote meeting platforms such as Canvas, Zoom, Teams, Google Meet, or Webex, designed to promote student learning in the program curriculum. The following activities can be counted for attendance reporting purposes:

• Educational interviewing (goal-setting, orientation, transition and pathway planning, completing assessments, portfolio development, etc.)
• Face-to-face classroom instruction and synchronous and asynchronous distance education instruction
• Tutoring
• Participation in a learning lab

Upon program entry a student record has Reportable Individual status for federal reporting purposes. All providers are required to track and report all attendance hours across all program areas. Once a student record has 12 or more attendance hours it has Participant status for federal reporting purposes and will be included in all WIOA performance accountability measures. If a student Exits a program and re-enters again in the same program year, they will start in a new Period of Participation as a Reportable Individual.

Optional Attendance Tracking

Tracking attendance beyond the minimum required  12 hours is optional as a method for determining post-test eligibility according to the Assessment Policy. Programs may decide to continue to track and report all attendance hours. Programs should check with partners to see if there are any other attendance tracking requirements for co-enrolled students using other funding sources.

Distance Education and Proxy Attendance Hours

Distance education hours for formal learning activities that occur outside the classroom may be counted and recorded directly as contact hours (for instruction offered synchronously via remote meeting platforms or other means where the learner identity is verifiable), by using the proxy hour methods defined in the Assessment Policy (fully asynchronous instruction), or by a combination of both contact hours and proxy hours in the case of hybrid instruction. Attendance hours for distance learners which are reported as contact hours may be a combination of actual contact and contact through telephone, video, teleconference or online communication, where student and program staff can interact and through which learner identity is verifiable.

The method for determining proxy hours and the amount of distance education hours available must be predetermined and included in the course syllabus. The course must be set up so the total hours possible match the credit hours (or weekly contact hours) of the course. For example:

1. A hybrid course that is 10 credits (5 synchronous hours & 5 asynchronous hours per week) that runs for 10 weeks would equal 100 hours of attendance. In this case, 50 hours reported for synchronous contact hours and 50 hours reported as asynchronous proxy hours.
2. An online only course that was scheduled to meet 6 hours a week for 11 weeks would report 66 attendance hours via an approved proxy method.

 

Sample Syllabus Statements for Courses with Distance Education

Below are sample statements for each distance education proxy hour model to demonstrate an acceptable way to describe each one in a syllabus. For ease of use, we recommend using the Learner Mastery Model. Additionally, this model can be programmed in Canvas using a grading scheme to calculate total hours at the end of each class. 

Learner Mastery Model

You will earn attendance for completing each course module (activities will be grouped by week in assignments). The amount of attendance you earn will be based on a percentage of the points you earn in the module.  This is the scale that will be used to determine the attendance you earn each week:

Teacher Verification Model

Online participation will count for attendance based on satisfactory completion of assignments. A time value for attendance is given for each assignment based on your instructor’s best estimate of how long an average student would need to complete the assignment. The time for each assignment is included in the course syllabus. The time you spend on task will be recorded as attendance hours.

Clock Time Model

Note: The Assessment Policy restricts use of this method. See the policy for more details.

Online participation will count for attendance based on the time you spend engaging in the online material using <software name> for a maximum of <# hours-minutes>. The time you spend on task will be recorded as attendance hours.

Hours entered in LACES cannot exceed the number of credit hours for which the course is designed. Refer to the SBCTC Policy Manual for guidance on determining credit values and credit equivalents.

Documenting Attendance Hours

Student attendance must be recorded and verified for all activities. Face-to-face attendance must be recorded daily by class, assessment session, tutoring session, or learning lab session. For distance education hours, attendance rosters must be kept by the instructor indicating the proxy hours awarded for each distance learning activity e.g., completed lessons, assignments, or assessments.

The original attendance sheet where the instructor manually or electronically marked the student attendance becomes the source document and must be retained as part of the student record.

Reporting Attendance Hours

Programs are required to report attendance hours in LACES at least quarterly, although monthly or more frequent reporting is highly preferred. Reporting data in a timely manner according to a fixed, regular schedule is the key factor for promoting data quality.

Report face-to-face and distance hours separately.

Hours entered in LACES cannot exceed the number of credit hours for which the course is designed. Refer to the SBCTC Policy Manual for guidance on determining credit values and credit equivalents.

A unique student identification number is required for all BEdA students. As directed in RCW 28B.10.042, the social security number cannot be that identification number for any student, staff, or faculty. 

SBCTC-BEdA providers will use an official SBCTC LACES Intake Form to collect entry status data from BEdA students. The LACES Intake form includes all NRS-required information that must be reported in LACES, plus the Attorney General's approved wording for requesting the use of student SSNs for data matching purposes. See note in the next section about the SSN Disclaimer. Providers will collect a new Intake Form for each Period of Participation. 

All providers are to only request students to complete our Intake Form after admission is complete. Providers may not create a form combining college registration and BEdA intake information as federal funding rules prohibit BEdA providers from asking certain questions during registration. To be in compliance with federal funding regulations, providers must collect all of the required NRS data on students for reporting purposes.

Providers choosing to make any changes to the official SBCTC LACES Intake Form, including the development of an electronic form, are required to submit the draft form to BEdA Reporting for approval. Electronic signatures should be approved by the Office of the Chief Information Officer (OCIO). If developing an electronic form, please also submit specifications regarding the software you plan to use and your organization’s OCIO-approved electronic signature policy.

Records must be kept in accordance with the Records Retention policy; however, each program may determine the type of filing system in which hard copy records are stored. All records must be readily accessible for program monitoring. Please note that student disability paperwork should NOT be kept with BEdA student records.

Student records must include the following documents:

• The LACES Intake form – one form each Period of Participation when the student enrolls. 
• A record that includes CASAS appraisal score and all CASAS pre-test and post-test scores.
• Documentation if student is pre-tested in only one subject area.  Please see the Assessment Policy for more detail.
• Actual original record of attendance hours. Refer to Student Contact/Attendance hours above.
• Documentation that a student with 45 or more hours at the end of the quarter is not ready for post-test or anyone not post-tested.
• Exception Request Form, signed by program director AND documented evidence that the student is likely to make a gain on a post-test.
• Tuition Waiver

HS+ diplomas are considered under Verification of Graduation Requirements under 20-02-69487 in the Community and Technical Colleges Records Retention Schedule. Documents that must be kept for graduating students “include a copy of the graduation application, evaluation of student credits (earned and transferred) and final determination.”

All Basic Education for Adults (BEdA) students are charged tuition of $25 per student per quarter. BEdA providers must offer to waive the $25 charge for students who are unable to pay. BEdA students concurrently enrolled in a college I-BEST program and paying college tuition are exempt from the $25 BEdA tuition. No tuition waiver is required for co-enrolled BEdA and I-BEST students. Waivers are reported in SMS each quarter using the proper coding.

BEdA providers are required to develop, implement, and maintain a BEdA Waiver Policy document that includes the waiver as well as details the process and requirements for student requesting the waiver. A student requesting a waiver of the $25 will be required to complete and sign a program waiver form annually. The completed waiver form will identify the waiver requirement(s) met by the student. No further documentation will be required unless specified in a program’s individual Tuition Waiver Policy. Waivers will be submitted to the appropriate program designee for approval, and approved waiver forms will then be retained for 7 years per federal requirements.

Per the Local Basic Education for Adults Provider Data Quality Standards Checklist, each funded local provider must have written processes and procedures for the following:

• Documented procedure for requesting and collecting Social Security Numbers (including how to deal with missing numbers) and documenting informed consent to use the SSN for data-matching purposes.
• Written definitions for all data elements, including demographic measures and contact hours and has provided them to all appropriate staff.
• Has documented and uses a system for verifying that program staff are following state assessment and data policies and procedures.
• Goal-setting and orientation procedures as described in the Minimum Components which includes collecting intake information and placing students into the program.
• Documented procedures are in use for correcting errors and resolving missing data with correct information.
• Documented procedures are used for dealing with analysis problems and deviations.
• Documented procedures are used to verify that local data are collected appropriately, and that local reports accurately reflect data collected.
• Documented procedure for waiving BEdA student tuition as locally defined. Policies should identify forms of documentation to be retained in student files to substantiate the basis for waivers.