Missed Material

This post was updated on Dec. 2, 2019 to add a link to the July 2017 FAA memorandum clarifying the FAA's policy.

Q: Our local inspector insists that our part 147 program tracks student missed time by the minute and that the time be "made up" by the students. Is a student required to make up every minute that they miss?

Q: Our local inspector insists that our part 147 program tracks student missed time by the minute and that the time be "made up" by the students. Is a student required to make up every minute that they miss?

A: Title 14 CFR § 147.31(e) requires that a part 147 program "use an approved system for determining final course grades and for recording student attendance. The system must show hours of absence allowed and show how the missed material will be made available to the student."

Make-up time is not mentioned in the regulation; however, inspector guidance found in FAA Order 8900.1, Vol. 2, Ch. 12, Section 2, paragraph 2-1449(G) directs local inspectors to ensure that the program "show hours of absence allowed and how the missed material will be made available to the student." It also states that "a student must complete all makeup assignments, class assignments, and exams missed in a module before an instructor can administer any written, oral, or practical test."

So no, the regulation does not require that students make up missed time. Programs are; however, expected to adhere to absentee policies, make missed material available, and ensure that students take requisite exams. If an instructor makes an assignment mandatory, then student completion must be enforced by the program.

To ensure appropriate policies are in place, and that they are properly communicated to school administrators, personnel, and those with oversight authority, ATEC suggests incorporating the following language in the program's operations manual to address the regulatory requirement--

Instructors will ensure students complete all missed practical projects.

Instructors will make missed lecture material available to the student in a manner the instructor deems most appropriate given the content missed. Missed material may be made available through--

• Communication of subjects and/or chapters covered in a course textbook;
• Availability of an instructor presentation;
• Availability of class materials; and/or
• Assignments directly attributed to the missed subject matter, such as, supplementary reading assignments, student completion of a written assignment or quiz, or a student oral presentation based on an outline.

Students are expected to take advantage of the materials made available to ensure proper understanding of any content missed, and successful completion of course assignment and tests.

In a July 12, 2017 memorandum, the FAA confirmed that schools need not “make up missed time,” so long as the school has in place an absentee policy (as required by § 147.31(e)) and ensures the missed material is made available to the student.