Last Day of Attendance: Audit Results Should Have You Check Your Aid Procedures
Published by: Russ Poulin | 8/27/2010
Just a hint…you may want to review your financial aid processes for distance education.
Thank you to Michael Jortberg from Acxiom for alerting me to a small item in this morning’s Chronicle of Higher Education postings: Audit Finds Errors in Baker College’s Distance Education Attendance Records. As you may know, WCET has been following this issue with the help of Dow, Lohnes Government Strategies. We have conducted a survey of members on this issue and issued a joint letter with ACUTA and UPCEA to the Department.
Over a several year period, the U.S. Department of Education has been reviewing the “last day of attendance” calculations for students who unofficially withdraw or drop-out of their online courses. From a brief from Dow, Lohnes Government Relations on this issue:
“if the institution is not required to take attendance, as is the case with many collegiate institutions, the institution may either use the mid-point of the financial aid payment period as the effective withdrawal date or it may choose to document the student’s LDA in an ‘academically related activity.’”
As a result of the audit, Baker College will have to refund $9,790 in financial aid funds for a handful of errors found through the audit process. They are asked to review the records of an additional 2,238 students and reimburse the U.S. Department of Education for any amounts that do not meet the standards laid out in this audit report. Baker College is also asked to verify the first day of attendance for these students, which is new to me. But, I’m not a financial aid person.
Now, an amount just under $10,000 does not sound like much. Undoubtedly, this has already cost considerable staff time and will require more staff time to perform the reviews of the records of each of these students. A large amount of additional reimbursements will probably ultimately be uncovered.
WCET is not in favor of sloppy procedures or defrauding the government. We just want clarity in definitions.
The U.S. Department of Education cited Baker College for a lack of definitions in its findings including criticizing it because it “did not provide a definition of ‘academic posting’ to its instructors.” Similarly, we would like to see clear definitions and guidelines provided by the Department on this issue. Colleges should not to have to wait for audits to see if their procedures are in compliance.
Our most recent letter to the Department concludes:
Given the importance of this matter for a great many institutions, we request that the Department define prospectively the documentation that our institutions may use to evidence LDA for online programs that would be effective beginning with the 2011‐2012 award year. This would provide sufficient time for institutions to make any modifications to their systems and procedures to comply with the Department’s new definitions. We also request that the Department take no adverse action against any institution for its LDA calculation until the Department issues that definition.
Meanwhile, what should you do?
If you are a distance education or financial aid administrator, I’d read this audit report and ask myself, “Do our procedures meet the standards cited in these findings?”
Research & Analysis