Chapter 19: CALPADS Reporting and Audit Compliance

Separate Tracking Requirement

EC §46211 is explicit: “Average daily attendance generated through an attendance recovery program shall be tracked and reported to the department separately from a pupil’s regular day attendance.”

In practice, this means your data systems must distinguish two streams:

• Regular-day attendance → Standard ADA calculated and submitted through PADC
• AR attendance → Separate ADA credit, reported through both PADC and STAS Field 13.24 in CALPADS

The separation matters because AR recovers revenue without changing a student’s attendance record. A student absent 12 days who earns 8 AR days still shows 12 absences. The district gets ADA apportionment for those 8 days — that’s the fiscal recovery. CALPADS keeps both data points in separate fields so CDE can calculate traditional and alternate chronic absenteeism rates independently.

PADC Reporting at P-1, P-2, and Annual Periods

Principal Apportionment Data Collection (PADC) runs three cycles per fiscal year. For 2025-26:

• P-1 (First Principal Apportionment): Based on data through roughly November, certified in December 2025 (completed)
• P-2 (Second Principal Apportionment): Based on data through January, certified in February 2026 (completed)
• Annual (Final Apportionment): Based on full-year data, certified summer 2026 (upcoming — this is your biggest window)

AR days earned before each reporting cutoff should be included in that period’s PADC submission. Districts that launched AR early — July or August 2025 through summer or intersessional programs — had recoverable ADA to report at P-1 and P-2. Districts launching spring programs will capture AR days only at Annual.

This is why summer/intersessional start dates have a reporting advantage: they bank AR days across all three apportionment periods instead of just the last one.

STAS File Field 13.24: Cross-Reference to CALPADS Chapter

The CALPADS chapter (Section 3) covers Field 13.24 in detail — how AR days are calculated, validation rules, the relationship between STAS and PADC, and the alternate chronic absenteeism rate. Here’s the summary for quick reference:

• Field 13.24 lives in the STAS (Student Absence Summary) file, submitted during End-of-Year (EOY) in May 2026
• Valid range: 0-10 days
• CALPADS validates that AR days don’t exceed the student’s total absences — at both school and LEA level
• The alternate chronic absenteeism rate, incorporating AR data, will be published by CDE in late 2026. It won’t affect the 2026 Dashboard but establishes a baseline for future accountability

Your AR tracking system must produce Field 13.24 values that match your PADC submissions exactly. If CALPADS shows 6 AR days for a student but PADC claims 8 in ADA recovery, auditors will flag the discrepancy. One data source should feed both systems.

Maintaining Backup Documentation

Clean CALPADS and PADC submissions get you through the door. Auditors go further — they’ll request the records behind every AR day you claimed. The CALPADS chapter (Section 3) details documentation standards; here’s the operational checklist:

For every AR day reported, produce:

1. Session attendance records — Sign-in/sign-out sheets with dates, times, and locations. Digital records with timestamps are stronger than paper sign-in sheets.
2. Teacher credentials — Valid California teaching credential for each AR supervisor, plus verification they’re an LEA employee (not a contractor). Keep copies on file; don’t rely on HR systems alone.
3. Instructional time logs — Total minutes per session, with a breakdown of qualifying instructional time vs. non-instructional time (transitions, snacks, breaks). This is what auditors use to verify your hour-to-day conversions.
4. Curriculum documentation — Lesson plans or scope-and-sequence showing alignment to grade-level standards. “Substantially equivalent” to the regular program is the statutory standard — have evidence that demonstrates it.
5. Ratio verification — Roster counts showing sessions stayed within 10:1 (TK/K) or 20:1 (grades 1-12). If a session had 22 students and one teacher, that’s a finding regardless of what your final data shows.

Store everything in one place — a shared drive, document management system, or compliance folder organized by site and date. Don’t let records scatter across individual teacher laptops, email attachments, and filing cabinets at different schools. When the audit request arrives, you want to pull a complete student record in minutes, not days.

What Auditors Will Verify Starting FY 2025-26

AR is new. Audit procedures are still being developed. But the statute and parallel program audits (ASES, ELO-P) point to seven areas auditors will check:

1. Student caps — Did any student exceed 10 AR days? Did any student’s AR days exceed their documented absences? Both are hard CALPADS validations, but auditors will verify the underlying data independently.

2. Eligibility — Were AR participants enrolled in classroom-based programs? (Independent study students aren’t eligible.) Were students enrolled in your district on the dates AR was claimed?

3. Teacher qualifications — Were all sessions supervised by certificated teachers with valid credentials? Were those teachers LEA employees?

4. Student-teacher ratios — Did any session exceed 10:1 (TK/K) or 20:1 (grades 1-12)? How was compliance documented?

5. Instructional quality — Was instruction aligned to grade-level standards? What evidence supports “substantially equivalent” to the regular program?

6. Time-to-day conversions — Did you use correct grade-level minute thresholds (180/230/240)? Were conversions accurate? How did you handle partial-day accumulations?

7. Separate tracking — Can you demonstrate that AR attendance was tracked and reported separately from regular-day attendance, as EC §46211 requires?

The first year carries higher stakes than usual. CDE, county offices, and the Legislature are watching how districts implement AR. Districts with clean documentation and conservative interpretations will navigate scrutiny. Districts with sloppy records or aggressive claims will face findings — and findings mean revenue adjustments.

Audit Preparation Best Practices

Document as you go. Don’t wait for an audit notification to organize records. If your staff can’t pull complete documentation for a randomly selected student within 15 minutes, your system isn’t audit-ready.

Run quarterly self-audits. Pull 10-20 random student records each quarter. Verify that every AR day has complete backup documentation — session attendance, teacher credentials, time logs, lesson plans, ratio verification. Gaps in your sample mean gaps system-wide. Fix them before the state finds them.

Write it down. Board-approved or cabinet-approved policies covering AR eligibility criteria, session structure requirements, teacher assignment protocols, and time calculation methods prevent inconsistencies across sites and staff turnover. When an auditor asks “how did you determine this student was eligible?” you want to point to a written policy, not an oral tradition.

Train everyone who touches AR. Teachers need to know what documentation they’re responsible for. Coordinators need to understand time calculation rules. Data techs need to know how STAS and PADC submissions connect. Compliance isn’t one person’s job — it’s the chain of people from session sign-in to CALPADS certification.

Check the CALPADS submission calendar. EOY opens in May 2026. Dates shift; check the CDE CALPADS page for the latest schedule. Build your data preparation timeline backward from the submission deadline, not forward from when you “get around to it.”