Attendance
in Online Courses
Draft Resolution
Background
Problem
Solution
• Definition and documentation of
attendance in fully online courses
significantly impacts students with
financial aid
• When a student receiving Title IV grants and
loans withdraws from a program, the student’s
institution must determine the amount of
assistance the student earned to calculate the
amount of unearned funds that must be returned
to the Department of Education
Background
Problem
Solution
• There is increased oversight of federal student aid
for distance education programs by
U.S. Department of Education
• U.S. Department of Education is scrutinizing
“last day of attendance” calculations for financial
aid students who unofficially withdraw or drop-out
from their online courses
• “Last day of attendance” is used to
determine the amount of aid a
student is eligible to receive when
he/she withdraws or leaves a course
Background
Problem
Solution
• Victims of online financial-aid fraud in 2009*
–
–
–
–
Axia College at University of Phoenix
Lansing Community College in Michigan
Dallas County Community College in Texas
Rio Salado College in Arizona
*According to the
Inspector General’s
report to Congress
Anatomy of an Online-Education Scam
Background
Problem
• Office of Federal Student
Aid to increase program
reviews of student-aid
operations next year by
50%
Solution
• Audit-like examinations
of student-aid operations
designed to ensure that • Students receive only the
grants and loans they are
entitled to
• Institutions make refunds
in accordance with the
law in cases where
students withdraw
Background
Problem
Solution
• Baker College audited
by U.S. Dept. of Education
• College did not maintain records that were adequate to
support its determination of student attendance during
2006-2007
• College incorrectly identified when distance education
students began and ceased attendance
• Result
• Baker College was required to reimburse the U.S.
Government thousands of dollars in financial aid funds for
errors found and is subject to additional audits to verify
the first day of attendance for these students
Background
Problem
Solution
• Dept of Ed recommends:
– Develop and implement written
policy and procedures for attendance
• Policy and procedures should address maintenance
of records adequate to support student eligibility
for financial aid
– Ensure that the specific date is documented and retained
in accordance with the record retention requirements in
those cases where the institution has chosen to use the
last date of academic activity as the last date of
attendance
Background
Problem
Solution
• There is no standard measurable definition of "last
day of attendance" for fully online courses at Foothill
• College must document student’s Last Day of
Attendance in an “academically related activity”
• US Department of Education may no longer
accept last login as sufficient for the definition of
"last day of attendance" for the purposes of federal
financial aid
• Student-tracking is NOT sufficient for
defining attendance for purposes of
financial aid
Background
Problem
Solution
• Develop a college policy and/or definition to
establish more accurate attendance record-keeping
for online courses
• Advantages to clearly defining and reporting
attendance in on-line courses include:
• Reduce federal and state audit liabilities/exceptions
(compliance, enrollment status, benefits receipt)
for financial aid recipients
• Reduce amount financial aid recipients
must repay to federal agencies
• Reduce amount Foothill College must
pay for financial aid recipients to
federal agencies
Background
Problem
Solution
• Attendance must be based on student’s
Last Day of Attendance in a documented
“academically related activity”
• Acceptable
– Meaningful participation in an online discussion
– Student initiating contact with a faculty member to
ask a course-related question via email or chat room
– Quizzes, tests, assignment submission
• Unacceptable
– Student-tracking of course site login
– Student posting of bio in Discussion forum
Foothill Faculty Senate
DRAFT Resolution
Student Attendance in Online Classes
• In compliance with federal requirements to document student
attendance in online classes, faculty must record a weekly
academically related activity such as discussion forum posting,
online quiz, reflection, assignment, exam, email, field trip,
telephone call or electronic communication at least through week 7
or the drop with “W” deadline for each student in an online class.
• This is in line with our commitment to best practices of “Regular,
Timely and Effective Student/Faculty Contact” as approved by the
Faculty Senate and submitted by faculty on the "Course Approval
Application for Online/Distance Learning Delivery" and vital to
students receiving financial aid.