2024-2025 Pupil Accounting Manual

The Michigan Department of Education (MDE) recently published the 2024-2025 Pupil Accounting Manual (PAM) and a Notable Changes document that identifies key PAM revisions. Significant PAM changes are outlined below.

Resident Pupils

The updated PAM states that a school may count the following as a resident: “A pupil who has been assigned to a district through a court order, where the assigned district does not contest the enrollment.” School officials should check board policies addressing student residency to determine whether policy revisions are needed to incorporate this PAM addition.

Student Records Maintenance

The updated PAM requires schools to maintain new document categories for auditor review. Now, in addition to transcripts and Education Development Plans, schools must maintain the following:

• Program of Study Records: Used to substantiate membership for early or middle college pupils who are accelerating through their program.
• Sequential Learning Timeline: Pupils enrolled in virtual learning (Section 5-O-D) must have a timeline documenting projected attempt dates for each virtual course on the pupil’s schedule.
• Learning Plan: Pupils participating in a dropout recovery program (Section 5-Q-A) must have a learning plan to be claimed in membership.
• Activity Logs: Used to document two-way interactions for virtual learning pupils (Section 5-O-D).
• Worksheets A and B: Used to document special education pupils under State School Aid Act (SSAA) Sections 52 and 53a.
• Training Agreements and Training Plans: Pupils engaged in a work-based learning experience (Section 5-P) must have these documents.

Appropriate Teacher Placement

For a student to be counted in membership, SSAA Section 6(8) requires that the student 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 student does not count for membership purposes.

Consistent with SSAA Section 6, MDE plans to issue state aid deductions for any teacher instructing outside the teacher’s grade level and content area endorsement. The updated PAM, however, contains the following exceptions to the teacher certification requirement:

• Courses capable of generating postsecondary level credit when instruction is provided by a professor employed by a postsecondary institution.
• An individual working under a valid substitute permit, authorization, or approval issued by MDE.
• Certain grade-level certified teachers of an alternative education learning lab.
• Periods deemed to be either a study hall or a non-subject area class require a grade-level certified teacher. No content area endorsement is required.

15 Days of Virtual Instruction

SSAA Section 21f allows schools to provide up to 15 days of virtual instruction without parent or legal guardian consent if the school creates a plan for virtual instruction, the plan is approved by the school’s board of education, and notice has been given to the impacted pupils and their parents or legal guardians before implementation.

Schools are required to provide their auditor a calendar that designates the use of such days where possible, including those used for student testing and professional development. MDE published an FAQ on this matter.

Special Education

The updated PAM reminds schools that students with disabilities are generally to receive a full day of instruction and attend the same number of days and hours as are required of any pupil to be counted as a full-time equivalent (FTE). If a licensed physician or a licensed physician’s assistant, following a diagnosis, provides a school with a reason to provide a pupil with a reduced schedule due to a medical or emotional reason, then the pupil may have reduced instructional time without impacting FTE. This reduced schedule must be determined by the individualized educational program (IEP) team and documented in the pupil’s records.

For special education pupils in a co-taught classroom, time classified as “special education” is time the special education teacher works with the pupil on IEP goals. The pupil’s IEP team calculates this time, which is documented in the special education provider’s pupil logs.

Revised PAM Section 2 clarifies that the hours an early childhood pupil with an IEP or an individualized family services plan receives only related services (not instruction) – such as speech, occupational therapy, physical therapy, or psychological or social work services – may not be counted for pupil membership purposes. Schools are required to abide by the standard day and hour requirements or the Michigan Administrative Rules for Special Education (MARSE), if applicable.

Additionally, PAM Section 5-K (Early Childhood Special Education Programs) was significantly revised. Those changes will be addressed in next month’s School Law Notes.

Homebound or Hospitalized Services

The updated PAM states that for a pupil with a disability who is receiving homebound or hospitalized services, the minimum two nonconsecutive hours of instruction per week during the count period applies even in weeks when school is not in session. For any homebound or hospitalized student, a homebound or hospitalized certification signed by an M.D. or D.O. must identify the medical condition that requires the pupil to be so confined.

Schools of Choice

PAM now reflects that a student who enrolls as a school of choice student under SSAA Section 105 or 105c is a student of the enrolling district until the student graduates, enrolls in another educational entity, or is expelled.

School Calendars

Schools must comply with their ISD’s common calendar when scheduling winter and spring breaks or changing the lengths of those breaks unless the school obtains a waiver from MDE. If a school wants to deviate from the ISD common calendar’s winter or spring break, its waiver request to MDE must document ISD support.

We recommend that school officials carefully review MDE’s Notable Changes document and PAM’s new requirements to ensure PAM compliance. Failure to comply with the PAM can result in significant state aid penalties.