Attendly Vault

2026-01-13 - FPM Compliance Framework

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Federal Program Monitoring (FPM) - Critical Compliance Insights for Attendly

California’s Federal Program Monitoring (FPM) ensures LEAs comply with federal/state categorical program requirements. For Attendly’s expanded learning customers, the Expanded Learning Programs (EXLP) Program Instrument defines all compliance requirements for ASES, 21st CCLC, ASSETs, and ELO-P.

Program Instruments: The Source of Truth

Program Instruments are comprehensive compliance checklists published annually by CDE containing:

  • Every federal and state legal requirement for each program area
  • Specific evidence needed to demonstrate compliance
  • Legal citations for each requirement
  • Examples of acceptable documentation

Critical for Attendly: Program Instruments are updated annually and determine whether districts pass or fail FPM reviews. CDE monitors use these as their official checklist during reviews.

Current instruments: https://www.cde.ca.gov/ta/cr/progrinst202526.asp

  1. Expanded Learning Programs (EXLP) - Covers ASES, 21st CCLC, ASSETs
  2. Fiscal Responsibilities for ELOP - ELO-P specific requirements

The 4-Cycle Review System

Every LEA is assigned to one of four cycles (A, B, C, D). Each LEA is reviewed once every 2 years, alternating between onsite and online reviews. Approximately 130 LEAs are reviewed annually (~65 onsite, ~65 online).

Rotation schedule:

  • Cycle A: Online in odd years (2024-25, 2026-27), Onsite in even years
  • Cycle B: Online in even years (2025-26, 2027-28), Onsite in odd years
  • Cycle C: Onsite in odd years (2024-25, 2026-27), Online in even years
  • Cycle D: Onsite in even years (2025-26, 2027-28), Online in odd years

2025-26 selections: None of Attendly’s current customers are being reviewed this year (verified against Cycle B online list and Cycle D onsite list).

Top 5 FPM Findings in Expanded Learning

Based on CDE analysis of most common EXLP violations:

EXLP 9: Funding Direct Services (85/15 Rule) - 15 findings

Requirement: ≥85% on Direct Services, ≤15% on Admin Costs (including Indirect), tracked by site.

Common violations:

  • Spending >15% on admin costs
  • LEA and service provider both taking 15% (double-dipping)
  • Applying 85/15 to grant total vs. by-site
  • Not tracking expenditures by site or resource code
  • Missing time accounting records (PAR, timesheets, certifications)

EXLP 11: Supplement Not Supplant - 11 findings

Common violations:

  • Misuse of categorical funds
  • Missing duty statements
  • Missing inventory records for purchases ≥$500

EXLP 13: Data-Driven Quality Improvement - 6 findings

Common violations:

  • No CQI process implemented
  • CQI process lacking explicit Expanded Learning Quality Standards integration

EXLP 15: Student-to-Staff Ratio - 8 findings

Requirement: 20:1 ratio (10:1 for TK/K)

Common violations:

  • Not maintaining required ratios
  • Missing or inaccurate attendance documentation
  • Unclear ratio tracking records

EXLP 16: Staff Minimum Qualifications - 8 findings

Common violations:

  • Missing policies on minimum qualifications, health screening, or fingerprinting
  • No records of health/fingerprint clearances
  • No documentation showing staff meet instructional aide requirements

The Enforcement Gap

FPM enforcement shows significant weaknesses:

Official process:

  • 45-60 day resolution deadline
  • Maximum 240-day extension
  • Authority to withhold/reduce funding (5 CCR §18056)

Reality:

  • Some districts have 10+ year old unresolved findings (View Park Prep: 3,576 days since 2015)
  • Major districts (Oakland, San Francisco, Sacramento) have findings 1,200-2,400+ days old
  • No apparent consequences beyond public listing and increased monitoring likelihood
  • System functions as voluntary compliance model rather than enforcement

Implication for Attendly: Weak enforcement means proactive compliance is optional for districts. Our value proposition must make compliance easier than non-compliance through automation and comprehensive tracking.

Platform Integration Requirements

Immediate Actions (Q1 2026)

  1. Annual instrument review process:

    • Download 2025-26 EXLP and ELOP instruments
    • Line-by-line comparison with 2024-25 versions
    • Identify requirement changes requiring platform updates

  2. Compliance coverage mapping:

    • Document which Attendly features address which EXLP items
    • Identify compliance gaps
    • Create feature-to-requirement matrix

  3. Customer cycle tracking:

    • Maintain database of customer FPM cycle assignments
    • Flag customers 12 months before review year
    • Enable proactive compliance support

Ongoing Process

Annual cycle (Q3-Q1):

  • Q3: Review newly published instruments (typically released late Q2/early Q3)
  • Q4: Implement platform changes for new requirements
  • Q1: Update documentation and customer communications

Feature priorities based on top findings:

  • 85/15 tracking automation by site
  • Time accounting record generation
  • Student-to-staff ratio monitoring with alerts
  • Staff qualification verification workflows
  • CQI process templates aligned to Quality Standards

Key Resources

Competitive Advantage

Attendly’s differentiation lies in turning complex FPM requirements into automated platform features that make compliance tracking effortless. Rather than reacting to findings, we enable districts to maintain continuous compliance through systematic monitoring aligned to Program Instruments.

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