II. Conclusions - Operational

TDLR Statement T1 (T1) states that PALMS is a transcript. In order for it to be considered a transcript, it must contain a “pass/fail” score. This requires more fidelity than pure attendance (A3). However, PALMS lacks any direct mechanisms (A5) to do so. Marking a student as graduated is not an acceptable indicator because a student that has transferred will have had all their hours marked as terminated (A9) regardless of successful completion, and they will still contribute to licensure (A10). Therefore, the only way to have a “pass/fail” score within PALMS is to state that all hours entered are “successfully completed”. This is further supported by TDLR’s signaled intent for these hours to assist in transitioning between schools(T2) (T4).

Attendance requires the ability to track both the hours a student is attended and the absences (A1)  (A4). PALMS has no way to do this (A4)  (A5). This is further supported by the fact that PALMS only tracks hours in the format matched directly used for determining licensing eligibility (A11), and not the way it’s taught (normal definition of attendance), nor the way TDLR lays it out in their required curriculum per 117.59(a). Further supported by the intended purpose of PALMS is for implementation of 455.2035, which is for combating human trafficking.

Conclusion 2 means that reporting cannot be done through PALMS. TDLR has provided no other mechanisms to report. This is further supported by the fact that only the school owner has an account for logging into PALMS (A7), and it would not be reasonable to expect a monthly reporting on a single individual in an entire organization without redundancy.

PALMS is considered a transcript per TDLR Statement T1, and TDLR has not yet implemented the reporting requirements (C3) that would force a release of some data.

PALMS data lacks the data required to be considered a transcript to a school receiving the PALMS data (T1). Also, there is not any indication if these hours trigger the additional record keeping requirements stated in 117.61(d). This is further supported by the fact that successfully completed hours listed in alone are not enough to convey successful completion of required curriculum (A12). A student may have successfully completed the first part of a subject multiple times, or the new school may teach a subject in a different order. Both result in the correct number of hours, or more, but without ensuring coverage of curriculum (A12).