How are you documenting and verifying instructional contact hours for online courses and course components when such activity is not documented by the online software program?
The followig OCTAE Memo indicates how you can track time. https://www2.ed.gov/about/offices/list/ovae/pi/AdultEd/octae-program-memo-20-3.pdf
States may, but are not required to, report in the National Reporting System (NRS) the time that participants spent on distance learning activities. Recording hours is useful for determining when a post-test should be administered. The NRS Technical Assistance (TA) Guide3 helps States that record distance learning hours by providing options for reporting “proxy hours” rather than classroom instructional hours. States that wish to record proxy contact hours may do so using one of the following models: • Clock Time Model, which assigns contact hours based on the elapsed time that a participant is connected to, or engaged in, an online or stand-alone software program that tracks time; • Teacher Verification Model, which assigns a fixed number of hours of credit for each assignment based on teacher determination of the extent to which a participant engaged in, or completed, the assignment; or • Learner Mastery Model, which assigns a fixed number of hours of credit based on the participant passing a test on the content of each lesson. Participants work with the curriculum and materials and, when they feel they have mastered the material, take a test. A high percentage of correct answers (typically 70%–80%) earns the credit hours attached to the material. The NRS TA Guide further advises that the State should use the