Palo Alto High School & Gunn High School
August 13, 2018
August 13, 2018

Independent Accountants' Report On Applying Agreed-Upon Procedures:
2018-19 Instructional Time Palo Alto High School & Gunn High School 

Christy White Associates (CWA) has performed the procedures enumerated below, which were agreed to by the management of Palo Alto Unified School District (“the District”), solely to assist you in reviewing the instructional time compliance for the proposed bell schedules and school calendars for Palo Alto High (“Paly High”) and Gunn High School for the 2018-19 school year.  The sufficiency of these procedures is solely the responsibility of the parties specified in this report.  Consequently, we make no representation regarding the sufficiency of the procedures enumerated below either for the purpose for which this report has been requested or for any other purpose. The procedures and associated findings are as follows:

Procedure #1:  CWA recalculated the annual instructional time of the proposed 2018-19 bell schedule and school calendar for Paly High and Gunn High and compared the results to the State’s minimum time requirements.  Any excesses and shortfalls are noted.  In addition, added time required to be made up from prior minutes shortfalls was included in the calculation.

Results #1:  Paly High School’s instructional time proposed for the 2018-19 school year meets minimum state compliance requirements, as recapped below.  There is sufficient excess time to make up the prior year shortfall of 535 minutes. 

Palo Alto High School Instructional Time for the 2018-19 School Year (As of August 1, 2018)
  Results
Total Instructional Days Proposed for the 2018-19 School Year 180
Total Instructional Time Offering Proposed for the 2018-19 School Year 66,760
State Minimum Time to be Offered in Grades 9-12 64,800
Proposed Instructional Time Offering in Excess of the State Minimum 1,960
In Compliance? Yes

Results #1:  Gunn High School’s instructional time proposed for the 2018-19 school year meets minimum state compliance requirements, as recapped below. 

Gunn High School Instructional Time for the 2018-19 School Year (As of August 1, 2018)
  Results
Total Instructional Days Proposed for the 2018-19 School Year 180
Total Instructional Time Offering Proposed for the 2018-19 School Year 65,729
State Minimum Time to be Offered in Grades 9-12 64,800
Proposed Instructional Time Offering in Excess of the State Minimum 929
In Compliance? Yes

The detailed bell schedules and calendar for each high school are included in the Attachments 1 and 2.

Procedure #2:  Apply State laws, regulations and California Department of Education (CDE) advisories to each instructional time element in the bell schedule and school calendar when determining compliance. The bell schedule elements included:  educational content and supervision for each class period offerings; breaks; passing time; flexible time early and late periods; and, other schedule element.  The calendar days were examined for compliance with minimum day requirements.  

Results #2:  For each proposed daily schedule CWA: (1) determined the class offerings were valid through discussion with each principal and considering the placement of the class time within the day and the nature of the class time; (2) confirmed the consistent use of passing time between classes and between days; and, (3) recomputed the instructional minutes.  CWA worked directly with each principal to ensure the instructional time was properly calculated, without exceptions.

Procedure #3:  Determine the allowability of tutorial time offering, considering placement of the tutorial time offered within each day and the length of tutorial time offered.

Results #3:  CWA sent an inquiry to Ruthann Munsterman at the California Department of Education. Her preliminary conclusion was that if the students are under the direct supervision and control of certificated staff the tutorial time would be countable as instructional time.  However, she also said that the broader topic of tutorial time would be taken up as a discussion item at a future CDE attendance meeting.  In the meantime, and for this project, CWA recommends including the tutorial time as instructional time.  Further research at Paly High found that the students cannot cut the tutorial class without consequences.  In other words; compulsory education is enforced like any other class period. Attendance is not optional, attendance is taken by certificated staff and the same early dismissal policies apply. There is direct certificated staff supervision the entire time in the tutorial class.    Whether the tutorial time is at the beginning, middle or end of the day would not matter since attendance is required. 

Procedures #4:  Determine whether InFocus time might be countable as instructional time. InFocus is a school produced news broadcast.  

Results #4:  Yes, the time is countable as instructional time since the students are under the direct supervision and control of certificated staff during the InFocus broadcast.

Procedures #5:  Determine the allowability of passing time as instructional time given the length of time and uniform application of time between classes.

Results #5:  CWA reviewed the daily schedules and determined that passing time is uniform within the day and as compared to other days.  The schools can count up to 10 minutes between valid course offerings as passing time.  CWA worked with the principals at each school to ensure the schedules were in full compliance with passing time requirements.

Procedures #6:  Determine if the instructional time for blended learning formats at both Paly High and Gunn High School are compliant.

Results #6:  Yes, the blended learning formats meet instructional time as the classes meet during the school day and are supervised by certificated staff.  

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the instructional time at Palo Alto High School and Gunn High School. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information and use of Palo Alto Unified School District and is not intended to be, and should not be, used by anyone other than the specified parties. 

Christy White Associates
August 1, 2018

PAUSD Agreed-upon Procedures: High School Instructional Time 2018-19 Report