On Line Programs
Carla Boren
Culver-Stockton College
Establish eligibility A school’s eligibility does not necessarily extend to all its programs,
so the school is responsible for ensuring that a program is eligible before
awarding FSA funds to students in that program.
In addition to determining that the program meets the eligible program
criteria given in this chapter, the school should make certain that the
program is included under the notice of accreditation from a nationally
recognized accrediting agency (unless the agency does not require that
particular programs be accredited).
The school should also make certain that it is authorized by the
appropriate state to offer the program (if the state licenses individual
programs at postsecondary institutions). In some instances a school or
program may need a general authorization as well as licensure for a specific
program approval. (See the chart on eligible institutions and the discussion
under Legal Authorization By a State in the FSA Handbook.
Distance Education
A distance education program at a domestic school is considered an
eligible FSA program if it has been accredited by an accrediting agency
recognized by the Department for accreditation of distance education. It is
not subject to the rules that apply to correspondence coursework.
Distance education means education that uses certain technologies to
deliver instruction to students who are separated from the instructor and to
support regular and substantive interaction between the students and the
instructor. The interaction may be synchronous (student and instructor are
in communication at the same time) or asynchronous. The technologies may
include the Internet, audio conferencing, or one-way and two-way transmissions
Through open broadcast, closed circuit, cable, microwave, broadband lines, fiber
optics, satellite, or wireless communications devices.
Cost of attendance - FSA Handbook Chapter 2
The cost of attendance for a student is an estimate of that student’s
educational expenses for the period of enrollment.
Averages may be used rather than actual expenses for like categories of students.
You can have different standard costs for different categories of students,
such as a cost of attendance for out-of-state students (who have higher
tuition) and a lower cost of attendance for in-state students. However, you
cannot combine the COA figures for each separate enrollment status and
award aid to a student on the basis of the average COA.
There are different ways to arrive at average costs for your students, such
as periodic surveys of your student population and local housing costs.
Tuition and fees - The tuition and fees normally assessed for a student carrying
the same academic workload. This includes costs of rental or
purchase of equipment (including equipment for instruction by
telecommunications), materials, or supplies required of all students in
the same course of study.
Books, Supplies, Transportation, Personal expenses – unless you are an online only
program, all schools are required to include transportation
Room and Board - For students without dependents
living at home with their parents, this will be an allowance that you
determine. For students living on campus, the allowance is the
standard amount normally assessed most residents. For those living
off-campus but not with their parents, the allowance must be based on
reasonable expenses for the student’s room and board.
For students living in housing located on a military base or
housing for which they receive a military housing allowance (Basic
Allowance for Housing, or “BAH”), the room and board COA
component shall include an allowance for board only. This applies
to:
•
independent students who receive, or whose spouses receive, a
military housing allowance (BAH) or who live on a military base;
and
•
dependent students who are living with parents who are receiving
a military housing allowance (BAH) or who live on a military base
Dependent daycare costs
For a student with dependents, an allowance for costs expected to
be incurred for dependent care. This covers care during periods
that include but are not limited to class time, study time, field work,
internships, and commuting time for the student. The amount of the
allowance should be based on the number and age of such dependents
and should not exceed reasonable cost in the community for the type
of care provided.
Determine reasonable cost - MDHE standard
Decide how to collect the data, form, interview, etc.
Other allowable expenses…
One time direct costs - fees in programs that require licensure or certification;
one time per student per program
Study abroad programs – reasonable costs associated with the program (get the
budget, add to student file for purposes of documentation
Allowances for disability - expenses include special services,
personal assistance, transportation, equipment, and supplies that are
reasonably incurred and not provided by other agencies
Allowance for expenses associated with cooperative education program associated
with employment
Loan origination fees - In all cases, you can either use the
exact loan fees charged to the student or an average of fees charged
to borrowers of the same type of loan at your school.
Exceptions to cost of attendance
• For students who are enrolled less than half-time, only the costs for
tuition and fees and allowances for books and supplies, transportation,
room and board for a limited duration, and dependent care expenses
may be included as part of the cost of attendance (miscellaneous
expenses and personal expenses may not be included)
Consortium agreements - A consortium agreement can apply to all FSA programs. Under a
consortium agreement, students may take courses at a school other than the
home school and have those courses count toward the degree or certificate at
the home school. A student can only receive FSA assistance for courses that
are applicable to the student’s certificate or degree program
A student receiving a Pell Grant for attendance at two schools through a consortium agreement may have
costs from both schools at the same time. The student’s cost of attendance is calculated in the same way
as for a student taking classes at only one school. The student’s charges for tuition and fees and books an
supplies at the consortium schools have to be combined into a single charge for a full academic year for
purposes of the Pell calculation.
The school paying the student may choose to use actual charges for the student,
which would simply be the sum of the actual charges at both schools. Of course, if the
student isn’t attending full-time, your school will have to prorate these tuition and fees
and books and supplies charges so that they are the correct amounts for a full-time, fullyear student.
If the disbursing school uses average charges, then the average full-time charges at
each of the schools must be prorated and combined. If the student is taking a full-time
load at each school, the full-time tuition and fees charges for an academic year at each
school can be averaged to determine the tuition and fee cost. However, if the student is
taking an unequal course load, the disbursing school must prorate the charges based on
the number of hours the student is taking at each school.
Attendance in On line programs –
New standards for the measurement for participation were put in place
within the last few years. No longer is a student signing in online proof of
participation. The institution is charged with being able to show proof of
participation. The standard for participation is determined by the
institution.
An example might be a submission to an online thread, submission of
homework. Login times are not sufficient.
Tracking attendance is key for purposes of Return of Title IV; a school must
be able to document the last date of attendance.
A school must have a policy in place to show management of nonparticipants.
3rd party agencies have been developed to satisfy the need for this
administrative responsibility.
Authenticating the online student’s identity – regulation requires
institutions to have a process in place to authenticate student identity
Examples…
• Increased emphasis on student portfolios, papers, projects, and quizzes in
exchange for high “point weighted” midterm and final tests
• Utilization of proctored assessments administered at sanctioned testing
centers
• Use of advanced technology intended to validate an individual’s
biometrics, including fingerprint readers, retinal scanners,
and facial or voice recognition programs
• Synchronous monitoring, including video surveillance, telephone callback, IP or cookie authentication, and software that
detects discrepancies in response patterns such as typing speed
• Complete avoidance of secure testing
Disbursement of funds…
Is the student eligible to receive the funds? Institutions will need to have something in p
to measure if the student is still eligible.
If there was a change of enrollment, you must recalculate the budget and aid to
discern if the student is still eligible… This can be very challenging.
Fraud
Online programs have become the target for people posing as students in order to
receive financial assistance. These are referred to as straw students or formerly Pell
runners.
Generally low-cost, open admission institutions are targeted as the refunds tend to
be larger, and the interaction between student and institution is done virtually.
Fraud tends to be found most often by the staff managing the back office duties;
verification, release of credit balances, etc.
Look for demographic information that shows up multiple times in admissions
applications, FAFSA’s, the same bank routing numbers used by multiple recipients, etc.
Fraud is required to be reported to the Office of Inspector General’s Fraud Hotline
Schools can modify disbursement rules for students participating
exclusively in distance learning programs, which would immediately
reduce the amount that fraud ring participants can receive. Schools
have the authority to:
Delay disbursement of Title IV funds until the student has participated
in the distance education program for a longer and more substantiated
period of time.
Make more frequent disbursements of Title IV funds so that not all of
the payment period's award is disbursed at the beginning of the
period.
*information taken from USDOE OIG slide presentation
Fundamentals of Title IV
Administration
Office of Inspector General
Investigation Services Overview
1-800-MIS-USED