March 9, 2020
Dear Superintendents and Charter School Leaders,

Last Friday, SDCOE Deputy Superintendent Mike Simonson attended a meeting of county office of education chief business officials. At the meeting, staff from the California Department of Education shared the following update regarding instructional minutes and attendance guidance in the face of the COVID-19 situation. 

By declaring an emergency, the material difference in ADA threshold of 10% is eliminated. A district can make the claim for even one student under the following conditions:

  • Need to record all students with reported COVID-19-like symptoms or in required quarantine.  
  • Students in quarantine or with symptoms cannot be claimed as independent study ADA; they are material difference in attendance. A district or school can put the student on independent study, but the attendance claim is through the waiver.
  • Independent study is appropriate for students who have no signs of COVID-19 but the parents are exercising caution to exposure. “I’m afraid to go to school” does not count toward material difference and must be reclaimed through independent study contract.
  • For school closures: Must have a letter from local health department for school closure with concurrence of the closure. Concurrence will waive all instructional minute requirements.  
  • School closure without consent from health department: If closure drops school below instructional minutes (minutes depend on grade of student), the financial penalty will exist in the audit; coming up short on instructional minutes is a huge penalty.  

If you have questions about this information, please contact Mike Simonson at

This is a fluid situation that continues to evolve. We will share additional information as it becomes available. Please don’t hesitate to reach out if you need additional assistance in the meantime.


Dr. Paul Gothold
San Diego County Superintendent of Schools
phone: 858-292-3514