2021-22 Pupil Accounting Manual

On September 30, 2021, MDE released the 2021-22 Pupil Accounting Manual (PAM). The new PAM is available at:


This article highlights changes to the PAM in three specific areas.

Virtual Learning

State School Aid Act (SSAA) Sections 6 and 21f and PAM Section 5-O-D apply strenuous requirements to virtual learning programs, including parental consent (unless the student is at least 18 or an emancipated minor), an educational development plan for each stu­dent enrolled in two or more virtual courses, and student participation requirements, such as two-way interactions between each student and the teacher of record (or mentor).

SSAA Section 21f contained a “pandemic learning” exception that suspended those requirements for the 2020-21 school year.

The new PAM, however, amends Section 5-O-D to remind schools that the “pandemic learning” exception does not apply for the 2021-22 school year. This means schools must return to meeting the more strenuous requirements for virtual learning.

Changes to PAM Section 5-O-D also clarify the process for counting virtual students in membership. For example, Section 5-O-D contains an FTE proration for partial satisfaction of the student participation re­quirement, a requirement that two-way interactions be maintained in a log for the entire school year, and a mandate that virtual students be reported in the “appropriate” school building.

Teacher Certification or Approval

SSAA Section 6 states that for a student to be counted in membership, the student must be in “attend­ance and receiving instruction in all classes for which the [student is] enrolled on the pupil membership count day or the supplemental count day.” MDE has long taken the position that if a student is not instructed by a certified teacher (or a teacher otherwise approved by MDE), the instruction received from that teacher is not a “class” and therefore the instruction does not count toward membership under SSAA Section 6.

In 2020, the Legislature amended SSAA Section 6 to add a requirement that the teacher providing instruc­tion must also be “appropriately placed.” PAM Section 1 now contains MDE’s interpretation of that phrase – the teacher must be teaching within the grade-level and subject area reflected on the teacher’s certificate or other MDE approval. Instruction by a teacher who does not meet this requirement will not count toward mem­bership. Importantly, PAM Section 1 states that the grade-level and subject area requirement does not ap­ply until the 2022-23 school year. MDE has taken the position, however, that to be considered “certificated,” all current teachers must be placed in the appropriate grade level.

Minimum Instruction Days and Hours and 75% Daily Attendance

PAM Section 2 now reflects that the minimum required days and hours of pupil instruction have been reinstated: each school must provide at least 180 days and 1,098 hours of pupil instruction each school year. The requirement that a school have at least 75% of its pupils in daily attendance has also been reinstated.

As a caveat, PAM Section 2 adds a formula that prorates state aid if a school does not meet the 75% daily attendance requirement. Specifically, the state aid penalty for not meeting the 75% requirement is the daily amount of state aid attributable to the number of the school’s pupils below 75% who were not in attendance.

This article describes only some of the changes to the PAM. We strongly recommend that school officials carefully review new requirements and clarifications in the PAM to ensure compliance. Failure to comply with PAM requirements can result in significant state aid deductions.