As districts transition to the new minimum school year reporting system, the Ohio Department of Education (“ODE”) recently released guidance about how it will allocate funding for students that attend school for less than a full day. In July of 2013, House Bill 59 became effective and mandated that the state funding formula for schools be based on annualized full- time enrollment (“FTE”). In order for a district to receive full per pupil funding, each student is expected to receive instruction for the entire day that the student’s grade level is scheduled to attend.

However, school districts typically have a number of students that do not attend for a full day, including students who participate in alternative school programs or who receive home instruction. Currently, districts are required to report in EMIS the percent of time that these students attend school as compared to the full day. In its guidance, ODE states that schools may experience a decrease in funding for part- time students as follows.

Alternative School Programs

Many students who are enrolled in alternative school programs are given the option to complete online modules independently. Often these students do not attend school for the entire day. According to ODE’s guidance, beginning this school year districts will be expected to provide an entire day of instruction for alternative school students unless they apply for and receive a waiver from ODE. ODE cites ORC §3313.533(B)(1), which states that an alternative school student must attend school or participate in another program named in the district’s plan for a period equal to the minimum school day mandated by state law. ODE states that a district may obtain a waiver if it can demonstrate that “the minimum hourly requirements are not workable for a particular student population.”

Districts that wish to apply for a waiver this school year are instructed to submit an email request to ODE at

Home Instruction

ORC §3323.12 requires a board of education to provide home instruction for children with disabilities who are unable to attend school. The statute further clarifies that for the purpose of determining formula ADM, five hours of home instruction is equivalent to five school days. Relying in part on this statute, school districts sometimes place students temporarily on home instruction, and provide five hours of instruction each week to ensure full funding. However, ODE notes that unless an IEP expressly requires home instruction, students who receive home instruction for less than a full day, including special education students, must be reported in EMIS as attending part-time.  These students may trigger a percentage reduction in funding as a result.

Senior Late Arrival and Early Release

For years, school districts have rewarded seniors who have completed most of their graduation requirements early with the option to arrive late or leave early from school each day. Beginning this summer, ODE indicated to districts that these students must be reported as attending school part-time. ODE recognized in the new guidance that districts may lose funding for the percentage of time the seniors are out of school because of late arrival or early release.

However, ODE also indicates that districts may apply for a waiver from the state superintendent that would allow them to count certain seniors who miss one period of class as fully enrolled, but only if those students take sufficiently rigorous courses. The guidance includes several examples of what would be considered “rigorous” for the waiver, such as when a student 1) takes two or more AP classes; 2) takes two courses through a dual enrollment program, or 3) completes a certain number of hours in an internship or apprenticeship program. A district that wishes to request this waiver/exemption should send the request along with a draft policy to

Work Release Programs

For work release, a district may count a student’s work time as instruction time if he/she participates in an official work study program or an approved educational option.  However, if a student has been released for employment due to financial hardship, a district has two options:

1) The district may report the student as part-time and include only the hours the student actually attends class (this is required if the absence is for more than ten days); or

2) Under certain circumstances, the district can count the absence as an excused absence if in accordance with board policy and approved by the district’s superintendent as an emergency or some other circumstance considered “good and sufficient cause” for an absence from school. Under this option, the absence will not impact the school’s funding but will affect the attendance rate.

Zero Periods

The last exemption for FTE that was included in the guidance involves zero periods.  A zero period occurs when a district offers an additional period of instruction that is optional for students.  With regard to the zero period exception, ODE will permit a district to report a student as attending full-time if he/she attends a district-created optional instruction period/zero period but is released from a period later in the day.

If you would like to view ODE’s guidance on Annualized Full- Time Enrollment, click here.

LEGAL REFS: ORC 3313.533, 3317.03, 3321.04, 3323.12