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Financial Aid and Distance Education
Calculating ‘Last Day of Attendance’ for U.S. Federal Financial Aid
In April 2010, Ellen Wagner and Russ Poulin were contacted about this issue by Ken Salomon and Chris Murray of the Washington legal agency of Dow Lohnes Government Strategies. In brief, the “last day of attendance” is to determine the amount of aid a student is eligible to receive when that student withdraws or leaves a program without officially notifying the institution. For online programs, some institutions use the last login of that student as the “last day of attendance.”Until the release of new regulations in October 2010, the U.S. Department of Education did not have specific guidelines on this issue, but is going by their standard of ‘academic engagement.’ While they determine this on a “case-by-case” basis, there is some interest in having a specific regulation on this practice.
- Federal financial aid review (audit) of Baker College stating: 'For distance education students who unofficially withdrew or dropped out, the College did not correctly identify when the students began and ceased attendance..."
- Dow Lohnes Government Relations brief on the `Last Day of Attendance` issue.
- Results of a survey of WCET members conducted to learn about institutional practices for determining ‘Last Day of Attendance’ for financial aid purposes. (May 2010)
- Letter to the U.S. Department of Education on the ‘Last Day o f Attendance’ issue co-signed by WCET, Instructional Technology Council, Association of Jesuit Colleges and Universities, and ACUTA. (June 2010)
- Letter on Last Day of Attendance in response to the U.S. Department of Education's Notice of Proposed Rulemaking (NPRM) on financial aid issues. Letter is co-signed by WCET, ACUTA, and the University Professional and Continuing Education Association on August 2, 2010.
- Letter from the U.S. Department of Education in response to the June letter. Sent August 23, 2010.
- On October 29, 2010, the U.S. Department of Education releases its ‘Program Integrity’ rules including a response to our concerns about definitions and the use of log-ins to demonstrate academic participation. The “Comments” begin on page 66898 (in the middle column) and the distance education wording is on page 66899 (in the bottom of the left column).
- A joint statement of concern from WCET and six other organizations is sent to the U.S. Department of Education on April 14, 2011. The letter objected to retroactive application of the regulations released in October.
- Response letter sent on May 12, 2011 by David Bergeron, Deputy Assistant Secretary, U.S. Department of Education.
- Letter to David Bergeron, Deputy Assistant Secretary, U.S. Department of Education, asking him to review the earlier letter. Letter was sent on July 29, 2011. We have yet to receive a response.
Fraud and Possible Abuse of Financial Aid Funds
The U.S. Department of Education (USDOE) seeks to assure that federal financial aid funds are used properly. Since the fall 2009 term, Congress, the USDOE, and the media have expressed increasing concern about the abuse of the financial aid process and outright fraud in the system. These concerns are often tied to unease with which some of these groups view online education.
Examples of Individuals Who Committed Fraud While Posing as Online Students
- Rio Salado College victimized:
- Wired Campus: Online Scheme Highlights Fears About Distance-Education Fraud
- Arizona Republic: 65 Indicted in Student Loan Fraud Against Rio Salado College
- Acxiom White Paper Underscores Need of Student Verification for Distance Learning. Although written by a vendor, the paper includes some examples of academic integrity and financial aid fraud.
Examples of Congressional Concerns about For-profit Institutions
- Congressional hearings on for-profit colleges (June 2010):
- Chronicle of Higher Education: Senators Vow to Crack Down on ‘Bad Actors’ in the For-Profit Sector
- Inside Higher Ed: The Senate Scrutiny Begins
At this point it is unclear what the impact may be on institutions offering online, distance, or hybrid courses. WCET continues to monitor this issue and inform its members.
