TEACHER CERTIFICATION FROM A

FLORIDA EDUCATION FINANCE PROGRAM

EXAMINATION PERSPECTIVE

PRESENTED TO THE

FLORIDA ASSOCIATION OF SCHOOL PERSONNEL

ADMINISTRATORS (FASPA)

By: Jennifer Taylor

Audit Supervisor

November 4, 2021

OBJECTIVE

To review the most common exceptions relating to

teacher certification found during a Florida Education

Finance Program (FEFP) Full-Time Equivalent (FTE)

examination and discuss how to proactively avoid

exceptions.

This presentation will discuss common examination

findings related to parent notification letters, out-of-

field status, and other topics to enable your District

School Board (District) to have the best FTE

examination outcome.

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WELCOME

Opening Remarks

▪ The Auditor General is the State of Florida’sindependent auditor.

▪ Pursuant to Section 1010.305, Florida Statutes, theAuditor General conducts FEFP examinations of therecords of Districts, as appropriate, to determinecompliance with State law and State Board ofEducation (SBE) rules relating to the classification,assignment, and verification of FTE studentenrollment, including teacher certification, andstudent transportation reported to the Department ofEducation (DOE) under the FEFP.

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AN EXAMINATION TRAIL

▪ Auditor General Preliminary Work Prior to theEntrance Conference with the District:

• Select teachers for testing purposes.

• Obtain listings of all courses taught by the selectedteachers.

• Obtain copies of the current certificates (valid duringthe examination year) on file using the DOE Bureauof Educator Certification application (VERSA).

• Compare the certification requirements in the DOECourse Code Directory and Instructional PersonnelAssignments (CCD) to the courses taught by theselected teachers and the subject areas listed ontheir certificates.

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▪ Auditor General Entrance Conference with

Personnel Director

• Discuss the overall approach to our test of teachercertification and inquire if there were anyinvestigations or legal proceedings initiated or inprocess.

• Provide a list of teachers where the subject areasdid not agree with the teachers’ certificates on file forfollow-up by the District.

• Obtain and review policies and procedures of theDistrict School Board and local Charter Boardestablished to comply with Florida Statutes, SBERules, and DOE guidelines regarding personnel.

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AN EXAMINATION TRAIL(Continued)

AN EXAMINATION TRAIL(Continued)

▪ Examination Work

• Review documentation provided in response to thelist given at the entrance conference.

• Work with District staff on outstanding issues.

• Develop findings and present to the District in theform of a Request for Comment (AG-424), ifapplicable.

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▪ Auditor General Exit Conference with

Personnel Director to Review the Findings

• Discuss findings and proposed adjustments.

• Certification personnel will generally have 1 weekto research the findings, obtain any additionalrelevant information that is available, and provide awritten response.

• After this, the auditor’s work will go through ouraudit review process and will result in thePreliminary & Tentative (P&T) audit report.

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AN EXAMINATION TRAIL(Continued)

CLARIFICATION #1

The Auditor General’s Office is the outside

examiner and is not the source for:

✓ Technical Assistance

✓ Policy or Procedure Questions

✓ “How To” or “How Not To” Questions

The DOE is the source for these types of

questions as the DOE is responsible for

implementing State law through rules and other

guidance.

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CLARIFICATION #2

▪ Statements of Eligibility are not certificateswith appropriate coverage.

▪ We examine valid and timely certificates todetermine compliance, by survey date.

▪ Issue date and validity date — are twodifferent dates used in our examinations:

• Issue date is the specific date the DOE adds asubject area to the certificate based on theteacher’s submitted application.

• Validity date is the fiscal year in which the DOEissues the certificate (3-Year Temporary or5-Year Professional).

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CLARIFICATION #2(Continued)

▪ Any subject area added to a certificate after theinitial issuance date has the same validityperiod as the initial certificate.

▪ Because the actual subject area is added bythe DOE on a specific date and is notretroactive to the validity period for examinationpurposes, we examine by survey date.(VERSA now more clearly identifies theeffective date on certificates when newsubjects/endorsements are added/issued.)

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CLARIFICATION #2(Continued)

EXAMPLE:

▪ Temporary certificate issued January 4, 2020, for

English and Math. The validity date for this initial

certificate is July 1, 2020, through June 30, 2023.

▪ The subject area of English for Speakers of Other

Languages (ESOL) is added to the existing

certificate in February 2022 but takes on, by default,

the existing validity date of that certificate.

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CLARIFICATION #2(Continued)

EXAMPLE (Continued):

▪ In our 2020-21 examination (FYE June 30, 2021),

we see the current certificate has English, Math,

and ESOL; however, even though the certificate

has a validity period (2020-23) that includes our

examination year, the ESOL subject area is not

effective until the issue date of that coverage (i.e.,

February 2022). If the instructor taught a course

requiring ESOL certification, the finding would be

that the teacher was teaching out of field (OOF) in

ESOL for the 2020-21 examination survey period.

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CLARIFICATION #3

Substitute Teachers and Use of Long-Term Substitutes

▪ There are two questions to answer:

(1) Is the substitute filling a vacancy or temporarilyreplacing a teacher on leave?

(2) Is the substitute providing direct instructionalservices to the students (creating lesson plans,providing student grades, etc.)?

▪ If the substitute is filling a vacancy and/or providingdirect instructional services, the substitute will betreated like a certified teacher and held to thecertification requirements. If not appropriatelycertified or not approved by the School Board toteach OOF, a finding will be prepared.

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COMMON EXCEPTIONS - FINDINGS

▪ Documentation of School Board approval or CharterSchool Board approval for teachers teaching OOF isnot on file.

▪ Parental notification of the teacher’s OOF status isnot on file. Placing the OOF list on the District Website is not sufficient parental notification. Parentsmust also be notified in writing either by personalletter sent home by mail, via the student, or in theSchool’s newsletter.

▪ Parental notification letter is not dated, has anincomplete date, does not identify the teacher, doesnot address that the teacher is teaching OOF, or doesnot identify the OOF subject area.

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COMMON EXCEPTIONS – FINDINGS(Continued)

▪ Documentation to support the required number of

in-service training points in ESOL strategies is not

on file.

▪ Documents are not timely in relation to survey

reporting (e.g., Board approval after survey).

▪ In-field status supporting documentation is not

maintained on file.

▪ Subject area is not in appropriate grade level of

instruction.

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PARENTAL NOTIFICATION REQUIREMENTS

▪ Section 1012.42(2), Florida Statutes, requiresnotification in writing. (Not merely a Web siteposting)

▪ Required elements to be covered in the writtennotification:

• Appropriate date (survey oriented).

• Specifics as to the identity of the teacher and thefact that the teacher is teaching OOF.

• Specifics as to the subject area (which must beincluded in the CCD) that the teacher is teachingout of field.

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HELPFUL INSIGHTS

▪ Maintain communication with the schools tospecifically identify teachers who are teachingOOF and the subjects they are teaching OOF.

▪ Do not presume that the teacher will fulfill therequirements needed and not present the teacherto the District School or Charter School Board. If,at the time of the survey, the teacher does nothave the proper certification, present the teacherto the School or Charter School Board as OOF.

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HELPFUL INSIGHTS(Continued)

▪ If it is close to a reporting survey period and theteacher’s application for subject area coverage ispending with the DOE, present the teacher as OOFto the School or Charter School Board.

▪ Stay abreast of the rules and statutes that areapplicable to the year in which the teacher isteaching, as the rules and statutes periodicallychange.

▪ Review the CCD for the proper subject area that isrequired for the specific course the teacher isteaching OOF.

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HELPFUL INSIGHTS(Continued)

▪ Career and Vocational Education versus Subject Area (i.e.,Any Health Ed Occ G versus Health 6).

▪ District experience-based certificate: cannot teach regularK-12 academic courses.

▪ Virtual teachers must be qualified when teaching courses,not just by Survey 4 when student funding is reported.

▪ Be aware of any endorsements (i.e., Reading, PKDisabilities, Severe or Profound Disabilities, ASD, Gifted,ESOL) that may be required pursuant to the CCD and thestudents enrolled in the course.

▪ SSN versus Contracted Services (CS) number: must useunique number to identify staff. Districts sometimes use aCS number to group multiple contracted staff.

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A TEACHER’S ROLE IN ACCURATELY REPORTING STUDENT FTE

▪ Attendance is one of the most important aspects ofdocumenting FTE eligibility for students. Teachersregularly completing attendance on the District’sStudent Information System is essential to providean audit trail and document source attendance.

▪ OJT timecards are the source attendance recordsfor students enrolled in Career Education (OJT)programs. Accurate and complete timecardsprovide documentation of attendance while thestudents are off campus. Teachers should ensurethat the students’ timecards are complete, dated,and signed by both the student and supervisor.

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THE EFFECTS of COVID-19

▪ DOE – Emergency Order (EO) No. 2020-02(May 13, 2020)

• Professional and temporary educator certificatesexpiring June 30, 2020, were extended andremained valid until December 31, 2020.

• Teachers not certified or endorsed in Readingwere allowed to provide intensive readinginterventions OOF until December 31, 2020.(DOE – EO No. 2020-07 – November 30, 2020,subsequently extended this allowance untilJune 30, 2021.)

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THE EFFECTS of COVID-19(Continued)

▪ DOE – Memorandum on Out-of-FieldTeachers (June 26, 2020)

• Many teachers who taught in an OOF positionduring the 2019-20 school year were unable tocomplete the college credits or in-service trainingrequirements.

• Districts could request that educators teachingsubject areas other than ESOL or Reading continuein an OOF assignment during the 2020-21 schoolyear without having completed the required collegecredits or in-service training.

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