Short-term independent study is how a lot of California families still keep a trip, a surgery, or a rough week from turning into unexcused days. The trap is treating it like a sticky note.
Do this first
- Pull the board policy. Find 14. Replace it with the 15-day line in Education Code 51747.
- Print audit guide section D.
- For the last 20 short-term pupils, can you show grade, school, program placement, the nine agreement elements, signatures in the right window, and a teacher who will own the time value?
It is a program. It has a written agreement. A certificated teacher has to judge time value. And since Senate Bill 153 (Chapter 38, Statutes of 2024, effective June 29, 2024 under Education Code 51747), the short-term line is 15 schooldays or fewer, not 14. CDE’s SB 153 independent study letter directs LEAs to use that definition beginning in 2024-25. If your board policy still says 14, you are behind the statute.
The 15-day line, in the actual code
Education Code 51747(g)(9)(A) splits the world in two.
More than 15 schooldays. Each written agreement shall be signed before independent study begins. Pupil. Parent, legal guardian, or caregiver if the pupil is under 18. The certificated employee designated for general supervision. The certificated employee designated for special education programming, as applicable.
15 schooldays or fewer. Same signatures. They shall be collected during the school year in which the program takes place. The agreement may be signed at any time that year. The Legislature’s intent, in the same sentence, is that parents or guardians get the agreement at or before the beginning of the school year.
Education Code 51747(i) is the other job that line does:
- Under 16 schooldays in a school year? Reengagement, sync plans, and the five-day return do not apply.
- Pupil enrolled in a comprehensive school for classroom-based instruction who, under the care of appropriately licensed professionals, is in independent study for necessary medical treatment or inpatient mental-health or substance-abuse treatment? Same exemptions, if you keep evidence from those professionals.
- Those rules live in subdivisions (d), (e), and (f). The 15-day line is not a hall pass on the agreement, the teacher, or ADA.
What changes at 15 schooldays
| Test | 15 schooldays or fewer | More than 15 schooldays |
|---|---|---|
| CDE name | Short-term. Fewer than 16 school days. CDE independent study guide. | Long-term. 16 school days or longer. CDE SB 153 letter. |
| Written agreement | Still required, with every element in EC 51747(g). | Still required, with every element in EC 51747(g). |
| When signatures land | During that school year. Statute wants the form in parents' hands at or before the year starts. EC 51747(g)(9)(A)(ii). | Before independent study begins. EC 51747(g)(9)(A)(i). |
| Reengagement, sync plans, five-day return | Do not apply if the pupil participates for fewer than 16 schooldays in the school year. Also off for classroom-based pupils who, under the care of appropriately licensed professionals, need independent study for necessary medical treatment or inpatient mental-health or substance-abuse treatment, with evidence on file. EC 51747(i). | Apply, unless the pupil is in that same licensed medical or inpatient-care group. EC 51747(d) through (f), EC 51747(i). |
| ADA | Time value of work, judged by a certificated LEA teacher, plus documented synchronous minutes if you use them. No three-day minimum. EC 51747.5, EC 46300(e). | Same ADA tests. EC 51747.5. |
| Audit sample | Auditors include intermittent or short-term pupils (fewer than 16 instructional days). 2026-27 audit guide, section D. | Same section D file. Audit guide. |
Scheduled length of the agreement and days in a school year are not always the same pile. If a pupil stacks more than one short agreement, read EC 51747(i) with your counsel before you skip reengagement.
What SB 153 changed besides the 15-day line
CDE’s SB 153 independent study letter listed three independent-study changes for 2024-25. The 14-to-15 shift is one. The three-day minimum duration for districts and county offices to claim independent study ADA is gone: Education Code 46300(e) now includes independent study of any length, still no more than one day of attendance per calendar day. And asynchronous evidence may include work on an online or computer-based platform if the program documents participation, per Education Code 51747.5(b)(2)(A)(ii). A login is not a day. The teacher still judges time value.
Education Code 51744 already told boards, when they adopt the written policy, to consider more than one model for short-term and long-term placements. A single bloated master agreement that pretends every family trip is a full-year program is how clerks drown.
You still need a board policy, or you do not have ADA
Education Code 51747 and Education Code 51748 are the gate:
- No adopted, implemented written independent study policies? No independent study ADA.
- Those policies have to cover assignment windows, satisfactory progress, missed-assignment evaluations, grade-level content (including A-G in high school), the reengagement and sync plans that subdivision (i) turns off for short-term pupils, and a current written agreement for each pupil.
- Missing policies go into the audit guide, with loss of independent study apportionment, per Education Code 51747(k).
- No grade level, program placement, and school of enrollment on the written record? No apportionment.
- The 2026-27 audit guide, section D samples short-term pupils for that test.
Every required element of the agreement
CDE’s independent study guide and Education Code 51747(g) are the same list. If a field is blank, the agreement is not done.
What has to be in the written agreement
-
How work comes back
Manner, time, frequency, and place for submitting assignments, reporting academic progress, and communicating with a parent or guardian.
-
Objectives and evaluation
Learning objectives, methods of study, and the methods used to evaluate the work.
-
Resources, including a device
Materials and personnel, plus confirming or providing connectivity and devices adequate to participate and finish assigned work.
-
Your board policies, in writing
Maximum time between assignment and completion, satisfactory progress, and missed assignments before an evaluation.
-
Beginning and ending dates
Duration of this agreement. No independent study agreement is valid longer than one school year.
-
Credits or other accomplishment
The subjects or courses the pupil is enrolled in, plus course credits, or for elementary grades another measure that fits the agreement. CDE's independent study guide lists both on the same line.
-
Supports, named
Academic and other supports for pupils not at grade level, English learners, pupils with IEPs or 504 plans, foster and homeless pupils, and pupils who need mental health supports.
-
Optional, in those words
Independent study is an optional educational alternative. No pupil may be required to participate. Expulsion and suspended-expulsion placements also need the classroom-instruction alternative on the form.
-
The right signatures
Pupil, parent or caregiver if under 18, supervising certificated employee, and special education certificated employee when that applies. Each of those signatures has to be dated. 5 CCR 11702(a) says the agreement is not in effect until it is complete, signed, and dated. Electronic files and electronic signatures are allowed if they meet the standards in Education Code 51747(g)(9)(B) through (E).
Statute: Education Code 51747(g). CDE's independent study guide also wants general student data on the agreement: name, address, grade, school of enrollment, program placement.
A later checklist post can walk each box with a sample clause. For this week, print the nine and sit with whoever still emails a PDF after the family is already in Utah.
ADA is time value, not a circled date
Education Code 51747.5(a) puts independent study under the general supervision of a certificated LEA employee. Education Code 51747.5(b) is the money sentence. You may claim apportionment only to the extent of the time value of pupil work products, personally judged in each instance by a certificated teacher employed by the LEA, or that time value combined with documented synchronous instruction. If the sum meets the minimum day, you may credit up to one schoolday. Never more than one unit of ADA per pupil.
Work products may include asynchronous time on a computer-based activity, even without a paper product, if the program documents participation. Keep the hours, per Education Code 51747.5(b)(2)(A). Synchronous minutes add only when they augment time value, with evidence a certificated employee verifies, per Education Code 51747.5(b)(2)(B). Keep a grade book or summary of assignments, assessments, and grades, per Education Code 51747.5(d). Teachers do not have to sign and date each work product when they assess time value, per Education Code 51747.5(e).
Education Code 51747(g)(9)(B) through (E) lets you keep agreements, assignment records, work samples, and attendance as an electronic file. A PDF or JPEG of the original counts for audit. Electronic signatures are allowed if they meet Government Code 16.5 and the Title 2 digital-signature rules.
If the teacher cannot stand behind the time value, you do not have a day.
Who may participate, and who may not be forced
Education Code 51745(a) lets an LEA offer independent study, including travel study and study when a parent determines in-person instruction would put the pupil’s health at risk. A pupil with exceptional needs may participate only if the IEP specifically provides for it, per Education Code 51745(c). A temporarily disabled pupil shall not receive individual instruction under Education Code 48206.3 through independent study, per Education Code 51745(d). Home hospital is a different path.
Independent study is optional. The agreement has to say so. Education Code 51747(g)(8). You cannot assign a chronically absent pupil to a 10-day packet as punishment.
Independent study is not Attendance Recovery
I keep watching districts try to use a later packet to erase Monday.
CDE’s instructional time FAQ directs that a pupil cannot use later independent study to recover an earlier absence. Makeup for a missed day of classroom instruction is Attendance Recovery under Education Code 46211, or Saturday school under Education Code 37223 if you are a district or county office. Short-term independent study is concurrent instruction for days the pupil is actually in the program.
The 2026-27 audit guide, section HZ also checks that sampled Recovery pupils were not continually enrolled in independent study for longer than 15 days on the dates they participated in Recovery. Do not run both playbooks on the same hours and hope the file sorts it out.
If the leak you actually have is the Recovery packet, not the independent study agreement, read Absences Aren’t the Biggest Leak. Paperwork Is..
Partner districts have gotten through independent study and Recovery audits without drama, and they have collected the funding the statutes allow. The ones who did it were boring on purpose. Agreement first. Teacher judgment on the work. Separate registers. No invented days.
A worked week, without invented money
A grade 4 pupil will miss eight instructional days for a family trip. That is short-term.
Hand the family the agreement before the first missed day if you can. Dates match the eight days. Assignments exist. Device access is confirmed. While they are gone, the certificated supervising teacher has work due inside the board’s maximum time, with a real packet or a platform that logs participation. When they return, the teacher judges time value against the grade 4 minimum day. A day that misses the floor is not ADA. Collect any remaining signatures during the school year. Education Code 51747(g)(9)(A)(ii) lets you do that for short-term. It does not let you skip the form.
Do not mark the eight days present because someone promised a packet. Do not use those days as Attendance Recovery for last month. Do not wait until May to invent signatures for an October trip. I am not attaching a statewide dollar to the week. LCFF does not price one ADA for the whole state.
What I tell CWA directors this week
Pull the board policy. Find the number 14. Replace it with the 15-day line from Education Code 51747 and the CDE SB 153 independent study letter. Print audit guide section D. For the last 20 short-term pupils, can you show grade, school, program placement, the nine agreement elements, signatures in the right window, and a teacher who will own the time value?
If the answer is a shared drive named “IS_FINAL_v7,” you do not have a short-term program. You have a scavenger hunt.
Your SIS is your system of record. Attendly is your system of action. We do not replace the SIS. We also do not pretend a missing signature is a software problem.
FAQ
Is short-term independent study 14 days or 15? Fifteen schooldays or fewer. SB 153 moved the line for 2024-25. Education Code 51747(g)(9) is the signature rule. Education Code 51747(i) uses fewer than 16 schooldays in a school year for the reengagement and sync exemptions.
Can we collect signatures after the pupil is already gone? For a program scheduled for 15 schooldays or fewer, yes, during that school year. Get the form to families earlier anyway. That is the Legislature’s intent in the same paragraph of Education Code 51747(g)(9)(A)(ii).
Do we still need an agreement for a three-day trip? Yes. The three-day ADA minimum is gone. The agreement is not. Education Code 46300(e) and Education Code 51747(g).
Can we require it for chronically absent pupils? No. Independent study is optional. Education Code 51747(g)(8). Attendance Recovery shall not be compulsory either. Education Code 46211(c).
Does a later packet fix last Wednesday’s absence? No. CDE’s instructional time FAQ is direct. Use Recovery or Saturday school for makeup. Use independent study for the days the pupil is actually in independent study.
What will the auditor open? Section D of the 2026-27 K-12 audit guide. Short-term pupils are in the sample. Missing grade, school, or program placement is a finding. A thin agreement is a finding. Time value that nobody will own is a finding.
Where should we start? Change 14 to 15 in policy. Map one trip through one file. If the file cannot show the dates, the work, the teacher, and the signatures, you do not have ADA. You have a vacation.
Sources
- Education Code 51744
- Education Code 51745
- Education Code 51747
- Education Code 51747.5
- Education Code 51748
- Education Code 46300
- Education Code 46211
- Education Code 37223
- 5 CCR 11702
- CDE Guide to Independent Study
- CDE SB 153 Independent Study Impact Letter
- CDE instructional time FAQ
- 2026-27 Guide for Annual Audits, section D and section HZ
Where Attendly fits
See how Attendance Recovery runs in Attendly
Scheduling, certificated ratios, and the documentation trail a board or auditor can follow.
Attendance Recovery