Time & Learning Questions & Answers
The Education Reform Act of 1993 directs the Board of Education "to evaluate and define the amount of time ... students spend in the classroom" and "to prepare a plan to extend the time during which students attend school to reflect prevailing norms in advanced industrial countries." To assist in this process, the Board in 1994 appointed the Massachusetts Commission on Time and Learning to review the quantity, quality, and adequacy of school time in Massachusetts. With recommendations from the Commission and the Commissioner of Education, the Board adopted Student Learning Time Regulations on December 20, 1994.
The Department of Elementary and Secondary Education is providing this revised version of the Student Learning Time Regulations Guide, originally published May 1995, to answer questions frequently raised by school officials about the Student Learning Time Regulations. I urge you to read this guide thoroughly because there are several items that were not addressed in the original guide.
At its April 1998 meeting, the Board of Education amended the definition of core subjects in the regulations to read:
Core subjects shall mean the core academic subjects specified in G.L. c. 69, section 1D (science, technology and mathematics, history and social science, English, foreign languages and the arts), and the subjects covered in courses which are part of an approved vocational-technical education program under M.G.L. c. 74.
Other subjects shall mean subjects other than core academic subjects that are required to be taught pursuant to G.L. c. 71, sections 1 and 3, and other subjects approved by the school committee as part of the district's program of studies.
To ensure a minimum base of learning time for all students in the Commonwealth, annual hourly requirements have been established. School districts have the flexibility to develop program offerings that exceed these minimums in order to serve the needs of their schools and students.
Collaboration among teachers, principals, school councils, school committees, students, superintendents and the community is recommended in determining the program of studies a district will provide for its students. An important measure of the quality of these programs now is the Massachusetts Comprehensive Assessment System (MCAS).
I hope you find the information in this booklet helpful.
David P. Driscoll
Commissioner of Education
Table of Contents
Special Education / Alternative Education
Student Learning Time Regulations (603 CMR 27.00)
Q: How does the April 1998 amendment relating to core subjects in the Student Learning Time Regulations affect what can be considered structured learning time?
A: The amendment makes it clear that both "core subjects" and "other subjects," as defined in the Regulations, may be included in the calculation of structured learning time for students in the public schools. The amendment affirms that, within the context of the applicable statutes and regulations, school committees and superintendents are responsible for deciding such matters as specific courses to be offered and the grade levels at which they are offered. The amendment also increases awareness of the statutory requirements for curriculum, including those mandating health education and physical education.
Q: Who has the final say within the school district on what will be considered structured learning time?
A: The decision is made by the school committee and superintendent, with advice from school councils and the school community, within the criteria established by the Board of Education.
Q: Will the decisions made concerning what counts as structured learning time be consistent from school to school within a district?
A: Individual schools may make different proposals regarding their programs to the school committee. The school committee, with input from the superintendent, will make a policy for the district that either requires consistency or allows for variations.
Q: Do the regulations mandate a certain number of hours per subject?
A: No. Prior to 1996, the only requirement was sixty (60) hours per year for physical education. Subsequent to the Board of Education's repeal of that regulation, there is no regulation requiring a certain number of hours for any subject.
Q: Can time during which students are engaged in learning without a teacher actually present count toward meeting structured learning time requirements?
A: Yes, the time may count toward structured learning time if the learning activity in which the student is engaged is:
- consistent with the curriculum for study of a core subject or other subject approved by the school committee; and
- part of a program designed by a teacher.
Q: Does the time accumulated for structured learning need to occur within the traditional student day?
A: No. However, time spent outside of the traditional school day must comply with the guidelines of an independent study (see question 9), or community service learning (see question 11).
Q: Are schools/districts obligated to provide a full program of studies (900 elementary, 990 secondary annual structured learning hours) for all students? Are all students required to be scheduled to receive these minimum hours?
A: Yes, and yes.
Q: What is meant by "directed study?"
A: Directed study requires students to be engaged in activities directly related to their program of studies, and a teacher must be available to assist students. A directed study may occur in places such as a classroom, computer lab, or resource room. Traditional (non-directed) study halls are not considered "directed study."
Q: What is meant by "independent study?"
A: An independent study is a program that has the same rigorous course of study and standards as a core subject. It is contained within the regularly scheduled student school year under the direction of a teacher, is assigned a grade and credit, is individually designed, and is not to be assigned to large groups of students merely for the purpose of satisfying the annual hourly requirement. Any school/district using independent study as part of structured learning time needs to have guidelines that clearly explain the process by which hours spent by students will be verified.
Q: Can community service be considered structured learning time?
A: No. Community service is volunteering time to participate in activities that, although worthwhile for individual communities, do not further the skills being taught in a core subject.
Q: Can community service learning automatically be considered structured learning time?
A: No. Community service learning is not listed in the Student Learning Time Regulations as an activity which can be considered structured learning time (603 CMR 27.02: Definitions "Structured learning time"). However, if a district has a community service learning component as part of its program of studies and that component follows the guidelines of an independent study (see question 9), then a maximum of twenty (20) hours within a school year may be considered structured learning time for community service learning. Examples include research on the growing cost to the community to maintain a homeless shelter, designing and building a bike path, or other projects where the student(s) would be directly using the skills being taught to them in a core subject.
Q: Have the annual hourly requirements for physical education been changed?
A: Yes. The Board of Education eliminated the mandatory minimum annual hourly requirement for physical education in 1996. However, physical education is a mandatory subject of instruction in Massachusetts public schools and is required to be taught to all students in all grades.
Q: Do physical education and health courses count toward structured learning time?
A: Yes. Since both health and physical education are required to be taught under state statute, these classes are considered structured learning time.
Q: Can students participating in any sport, whether it is school sponsored, intramural, extracurricular, or private lessons, use practice time to count as physical education or toward the annual structured learning time?
Q: Do programs/courses such as home economics, technical studies, business, school-to-work opportunities, etc. count toward structured learning time?
A: Yes. Programs and courses that a school committee approves as part of the district's program of studies may count toward structured learning time.
Q: Can guidance services be considered structured learning time?
A: Guidance services that are designed as programs with specific learning outcomes, that serve an educational or skill-building function, and have a specific scheduled meeting time can count as structured learning time. Examples include peer mediation training, teacher/student advisory programs, career planning, or scheduled counseling sessions. Students may not be excused from core subjects on a regular basis for guidance programs or services.
Note: Students who have been scheduled to receive 900/990 annual hours of instruction may receive emergency or immediate counseling services as part of these hours.
Q: Can students enrolled in one or more college courses count those courses as structured learning time?
A: The Dual Enrollment statute, G.L. c. 15A, s. 39, expressly permits a secondary student to "enroll either full time or for individual courses" in a public institution of higher education, and to earn both secondary school and college credits. Since the statute specifically allows full-time enrollment, it supersedes the 990-hour requirement of the Student Learning Time Regulations for any student who is enrolled full-time (i.e., taking a full course load) at a college or university. Students enrolled in one or two college courses, as opposed to a full schedule, not offered by the district may also count time spent in those courses toward their structured learning requirement.
Q: Can schools hold assemblies during the school day?
A: Yes. How schools choose to structure their day is locally determined. The content of the assemblies must be evaluated in determining whether or not the time spent is considered structured learning time. If schools schedule non-academic activities such as sports rallies, class pictures, etc., additional structured learning time needs to be scheduled into the year to accommodate those activities.
Q: Can travel time be considered structured learning time?
A: The key requirement for structured learning time is that a student be scheduled to receive a full program (900/990 hours). If travel is a part of the student's schedule (such as for field trips, community service learning activities, dual enrollment, or travel to a work site), then the school district may consider such travel as included in the student's schedule. The Department recommends that schools consider scheduling additional structured learning time when significant travel time is anticipated (i.e., time outside the hours of the regular school day).
Q: Can time lost due to inclement weather be counted under the "emergency or extraordinary circumstances" provisions?
A: No. The Student Learning Time Regulations require that districts schedule 185 days into their calendar to compensate for weather related closings. The Department recommends that schools schedule additional hours in consideration of delayed openings or early dismissals, and plan the school calendar to provide flexibility for such events without depriving students of a full instructional schedule.
Q: Can the days scheduled for early release for Thanksgiving, professional development, inservice, mid-term/final exams or parent/teacher conferences count as full days?
A: Those days may count toward the 180 student days, but only the actual time spent on structured learning can count toward the 900/990 hours.
Q: Can schools reduce lunch time in order to provide additional structured learning time?
A: Yes. However, the Department urges schools to provide all students with a reasonable lunch period so that students have an opportunity to talk to each other, and to develop and practice good nutritional habits.
Q: Can schools reduce/eliminate recess at the elementary level in order to provide additional structured learning time?
A: Yes. However, the Department does not recommend the elimination of recess at the elementary level.
Q: Can regularly scheduled structured learning time be reduced to provide such school services as health screenings and immunizations?
A: No. Such services must be provided in time scheduled in addition to the structured learning time. Schools should build extra time into the school year schedule to make sure that such services can be delivered without reducing the 900/990 hours required for structured learning time.
Q: Can schools continue to have a "freshman orientation" day(s) which results in the freshmen attending school for 180 days while the other classes attend for 179 or fewer days?
A: No. All students must be scheduled to attend school for 180 days per school year. Freshman orientation can be valuable for both students and faculty, so if the school district wishes to provide a freshman orientation day, it should do so in addition to the 180 day school year.
Special Education / Alternative Education
Q: What is the relationship between a student's Individualized Educational Plan (IEP) and the Student Learning Time Regulations?
A: Once the Team has developed the IEP and it has been accepted by the parent or guardian, the IEP defines the appropriate program for the student. All of the elements of the IEP provided by the school count as structured learning time.
Q: Are there special provisions for students enrolled in alternative education programs?
A: No. The same structured learning time requirements apply for students enrolled in publicly funded alternative education programs.
Q: Are there special provisions for part-time students?
A: All schools must make a full program of studies available to all students. However, there may be special circumstances where a school may agree to permit a student to attend on a part-time basis. Part-time students should be made aware that by not participating in the school's full program they may be jeopardizing their ability to meet graduation requirements.
Q: Do school systems that schedule two daily half-day sessions of kindergarten need to adopt a schedule that ensures equal instructional time for both groups of students?
A: Yes. All kindergarten students must be scheduled to receive a minimum of 425 annual hours of structured learning time.
Q: Do school systems that provide both full-day and half-day kindergarten programs need to adopt a schedule that ensures equal instructional time for all?
A: No. The requirement is that all kindergarten students be scheduled to receive a minimum of 425 annual hours of structured learning time.
Q: If a school system operates a full-day kindergarten program only, can parents choose to send their child for only the minimum 425 annual hours?
A: Parents who elect to send their children to a public school kindergarten must enroll their child for the full program unless the school district offers a partial day option.
Q: Can play time be considered structured learning time at the kindergarten level?
A: Yes. In early childhood programs, snack time, play time, clean-up time, and outdoor time offer children opportunities to develop fine motor, gross motor, self-help, language, and social skills. Therefore, districts may count these as structured learning time at the kindergarten level.
Q: Can a school housing grades 5-8 designate 5-6 as elementary and 7-8 as secondary?
A: No. The regulations require the school committee to designate each school as either an elementary or a secondary school prior to the commencement of the school year. However, a middle school designated as an elementary school could choose to provide, for instance, 900 hours for the 5th and 6th grades, and more hours for the 7th and 8th grades, as long as all students are scheduled to receive at least 900 hours of structured learning time.
Q: If a middle school defines itself as elementary, what is the appropriate certification of its personnel?
A: Regardless of how the school is categorized for structured learning time purposes, the staff must be properly certified for the actual grades served by the school. If a school contains grades 5-8, the staff must have certificates that cover the grades they are teaching.
Q: Will a school district's Chapter 70 state aid be affected if it identifies its middle school(s) as elementary rather than secondary schools for structured learning time purposes?
A: No. The district will complete the End-of-Year Report using the category available for middle schools, and the Chapter 70 aid will reflect funding appropriate to a middle school. The designation of a middle school as elementary or secondary is for the purposes of meeting the requirements of the Student Learning Time Regulations only.
Q: Are vocational schools accountable for the same structured learning time requirements and state assessments as comprehensive and academic high schools?
Q: How are the varying types of vocational program schedules considered in calculating the 990 hours?
A: All Chapter 74 approved vocational programs are considered structured learning time regardless of the type of schedule the school is using.
Q: What are the requirements regarding early release of high school seniors?
A: The earliest possible release day for seniors is twelve school days prior to the regularly scheduled closing date of the school. High schools that operate on a 180 day year for students may release the seniors as early as the 168th day of school. If the high school operates 183 days, seniors are to remain in school at least through 171 days. If districts schedule senior graduation on the 168th school day, seniors must be in class on graduation day. If graduation is scheduled after the 168th school day, seniors may be released prior to graduation day. Schools are not required to delay the date of graduation once it has been set or to keep seniors in school past the date of graduation.
Q: Are seniors required to receive the full 990 hours even though they may attend fewer than 180 days?
A: Seniors must have a schedule that would provide 990 hours if they were in attendance for the full 180 days of school. They may be provided with fewer than the full 990 hours if the district elects to schedule early release and/or graduation.
Q: May students who have fulfilled graduation requirements, or who need less than a full program of studies to fulfill graduation requirements, be scheduled into less than a full program of studies?
A: No. Districts must schedule all students into a full program of studies.
Q: Are schools/districts required to ensure that every student actually attends school for a minimum of 900/990 annual hours?
A: No. The school/district must ensure that each student has been scheduled to receive 900/990 hours of structured learning time. The student has the responsibility to participate in his/her scheduled program of studies.
Q: Are Commonwealth and Horace Mann charter schools required to operate under the Student Learning Time Regulations?
A: Yes. Charter schools are public schools and are subject to the Student Learning Time Regulations.
Q: How will the Department of Elementary and Secondary Education determine if districts are complying with the Student Learning Time requirements?
A: There are several ways the Department will monitor the implementation of the time and learning policy:
- Districts provide this information in their School Improvement Plans;
- The Department reviews Time and Learning Surveys submitted by districts;
- If complaints are filed with the Department of Elementary and Secondary Education alleging that a school or district is not meeting the Student Learning Time requirements, the Department will investigate the school or district program;
- The Department will review schools that are "underperforming" in accordance with state standards. One factor of the review will be the amount of structured learning time the school provides students; and
- The Department will review the performance of all districts through its new accountability system. Compliance with the Student Learning Time Regulations will be one component of that review.