February 14, 2008
NOTICE OF ELECTRONIC ATTENDANCE ACCOUNTING PILOT PROGRAM
AND TEACHER SIGNATURE ALTERNATIVES
Advances in technology present an exciting opportunity for local educational agencies (LEAs) to streamline attendance accounting. Accordingly, the California Department of Education (CDE) intends to allow an LEA to replace manual teacher signatures with a digital signature or other electronic certification process. To begin this transition to replace the manual process, we are developing an attendance accounting pilot program.
To better construct the pilot criteria, we are now requesting your input, to provide for our consideration practical alternatives to the current manual signature process. For this input, LEAs may want to collaborate with one another and with attendance system vendors on the design of a digital signature or an electronic certification process.
While supportive of streamlining administrative duties at the local level, the CDE’s primary concern is to ensure the integrity of attendance accounting in public education. Currently, we require that teachers manually sign and date attendance registers within a specified time frame, depending on the type of attendance accounting system used. For online attendance accounting systems, teachers generally sign and date a weekly printout of attendance records entered online during the previous week. As the eye-witness to a pupil’s presence or absence, a teacher’s dated signature provides a valid, contemporaneous record of attendance, ensuring a pupil’s compliance with compulsory attendance laws and providing the basis for over $30 billion in kindergarten through twelfth grade apportionment funding. A digital signature or an electronic certification process will need to continue to ensure that LEA employees are the only individuals taking and verifying attendance.
One alternative that the CDE has been investigating is the use of Public Key Cryptography (PKI) to create a digital teacher signature. California Government Code Section 16.5 defines a digital signature as “an electronic identifier, created by computer, intended by the party using it to have the same force and effect as the use of a manual signature.” California Secretary of State (SOS) regulations have established PKI as an acceptable digital signature technology for use by California’s public entities, provided that the digital signature meets the following requirements: (1) it is unique to the person using it; (2) it is capable of verification; (3) it is under the sole control of the person using it; (4) it is linked to data in such a manner that if the data are changed, the digital signature is invalidated; and (5) it conforms to SOS regulations, which are available on the California Digital Signature Regulations Web page at http://www.sos.ca.gov/digsig/regulations.htm (Outside Source). [Note, the preceding link is no longer valid.]
In addition to feedback on the possible use of PKI technology, the CDE would like to learn more about other technologies available to LEAs, and how LEAs could effectively integrate these new tools into current attendance accounting systems in a manner that provides for greater administrative efficiencies but still protects the integrity of attendance data. The CDE is particularly interested in details relating to system security, data integrity, audit ability, and costs (including any future savings) associated with the implementation of a new attendance certification process.
The CDE intends to use the feedback received from LEAs in the development of parameters for a pilot program effective fiscal year 2009–10. Therefore, we would appreciate your valuable comments by August 31, 2008. Please share this letter with your chief business officers so that they may share their insight as well.
If you have any questions or would like to arrange a meeting to discuss this new opportunity, please contact Kim Clement, Fiscal Consultant, School Fiscal Services Division, by phone at 916-327-0857 or by e-mail at clement@cde.ca.gov.
Sincerely,
JACK O’CONNELL
JO:el
1430 N Street
Sacramento, CA 95814