Dual-Funded Sites Attendance ReportingGuidance on reporting attendance for dual-funded sites.
A dual-funded program site is one that receives both state After School Education and Safety (ASES) and federal 21st Century Community Learning Centers (21st CCLC) funding for after school programs. Federal law requires grantees to use federal funds to supplement the current level of state, local, and other non-federal funds and in no case use federal funds to supplant or replace state, local, and other non-federal funds.
The purpose of this guidance is to ensure that grantees with dual-funded sites are able to record the attendance of students enrolled in either the ASES Program or the 21st CCLC Program so as to minimize the likelihood of an audit finding or an involuntary grant reduction.
California Education Code requires grantees to record actual student attendance for each day of attendance in either the ASES or 21st CCLC before and after school programs. The daily attendance shall be recorded for all the students attending the before and/or after school program on each school day the before and after school program operates.
Recording Attendance at Dual-Funded Program SitesHow student attendance is counted at a dual-funded site depends on how the program is operated.
- The site is operated as two separate programs with separate staff and activities. This is an instance in which two separate programs are simply located at one site without further connection. In this case, student attendance must be counted separately for each program and the student attendance counts are locked into only one of the programs.
- The site is operated as one program with shared staff and activities. This is an instance in which the two programs are operated as one. In this case, the program has the option of counting attendance in the following way:
- Student attendance should first be counted towards the state funded ASES up to 85 percent of the ASES attendance target.
- Only after 85 percent of the ASES attendance target has been met can the remaining attendance be applied towards the 21st CCLC Program.
In this second scenario, sites do not have to lock a student’s attendance into one specific grant for reporting attendance. Sites cannot report the same student to both grants on any given school day, in the attendance report submitted to the California Department of Education (CDE). However, there may be times when a student is counted towards the ASES Program grant on a given school day and to the 21st CCLC Program grant on another given school day depending on the fluctuation of daily attendance.
Possible Consequences to Grantees with Dual-Funded Sites
When following the above state procedures, the program complies with the supplement and not supplant requirements for the use of 21st CCLC Program funds. A dual-funded site runs the risk of an audit finding or involuntary grant reduction if they do not follow these procedures.
Note: Below is related guidance from the federal publication 21st CCLC Non-Regulatory Guidance – February 2003.
Question F-12: “Can state educational agencies (SEAs) award local grants to schools that already receive federal 21st CCLC Program funds?”
Yes. Communities that presently have a grant from the CDE are eligible to receive additional funds under the SEA-administered program. However, local applicants and SEAs should be aware that new funds must be used in a manner consistent with all the requirements of the new statute and must be used only to supplement, not supplant, any federal, state or local dollars available to support activities allowable under the 21st CCLC Program. Funds may be used to expand or enhance current activities, or to establish programs in non-participating schools within a local educational agency that has a 21st CCLC Program grant. School districts that have received 21st CCLC Program grant awards that have ended, or are ending this year, may apply to the SEA for funds to continue those programs. The supplanting provision does not prohibit federal funds from being used to continue programs where a previous federal grant has ended and other federal, state or local funds would not have been available.