1. O NLINE P ROGRAMS : C HALLENGES AND S OLUTIONS Melody DeFlorio May 18, 3014

2. Identify ChallengesIdentify Challenges 1 Discuss institutional solutionsDiscuss institutional solutions 2 Discuss long term ED solutionsDiscuss long term ED solutions 3 Goals

3. Distance Education Courses HEA Sec. 103 and 484(I) 34 CFR 600.2, 668.38 Distance education refers to instruction delivered to students who are physically separated from their instructor, to support regular and substantive interaction between student and instructor, whether in real time or through time delay

4. Distance Education VERIFICATION PROCESSING AID COA FRAUD Challenges

5. Educational Purpose Identity Citizenship Unusual enrollment History Verification

6. Identity and statement of educational purpose For students selected for verification tracking group 5: “A student who is unable to appear at the school must sign and submit the statement of educational purpose, and he must submit a copy of his ID with the statement signed by a notary public confirming that the student appeared before her and presented the ID confirming his identity” For students who are flagged in the V6 group who only qualify for non-need based aid, the verification of identity/educational purpose is not required.

7. Citizenship – US Citizens For Packaging Copy of birth certificate Copy of US Passport Form FS-240, report of birth abroad N-560, certificate of citizenship N-550, certificate of naturalization For Disbursement Original documentation of citizenship presented by student

8. Citizenship – Eligible Noncitizens DHS cannot confirm noncitizen status (Code 144) DHS Performs automated secondary confirmation Code 120 (Y) – Eligibility confirmed Code 105 (C) – not yet confirmed, wait 10 business days for new ISIR Eligibility Confirmed No Confirmation – Code 046 (N) School begins Paper Secondary Confirmation

9. Challenges : Original Documentation Finding secure methods to obtain original documents Frequent starts/rolling admissions Students may have a faster admissions process in the online environment. Clearing these issues quickly to get students their funds Students Nationwide Working with students around the country and out of the country to get the documentation required in a timely manner

10. Document Management Establish policies and procedures for accepting documents from distance learners Have system in place to return documents to a student Indicate a point person to handle all DHS flags and do necessary follow up Training Provide adequate training for staff on verification documents Communication Are departments communicating with one another? How can admissions help? What can the registrar do to expedite these processes? Solutions

11. Enrollment StatusAttendance Policy R2T4Overpayments Challenges of Processing Aid

12. Enrollment status Challenges Award/Refund Accuracy Communication EnrollmentParticipationEligibilityFinancial Aid

13. Enrollment status Challenges Award/refund accuracy Communication RegistrarFacultyFinancial AidEnrollmentParticipationEligibility

14. ‘Classroom’ Activity Confirming Participation Nonterm programs Module based programs Change in enrollment status: student vs institution at fault Add/drop policy: working with or against disbursement and refunding policies

15. Are you an institution required to take attendance? From FSA Handbook, Volume 6, Chapter 1 Discussion Posts Group Projects Submitting weekly assignments Administrative withdraw policy

16. R2T4 and Overawards Problem: Higher risk of overaward/overpayment Solutions: Routine monitoring of attendance Routine monitoring of enrollment status, particularly for module-based programs

17. C OST OF A TTENDANCE

18. Tuition and Fees Books, supplies Transportation Miscellaneous Room and board Dependent care Disability care Loan fees Exceptional Expenses* Allowable COA Costs

20. COA considerations Student by student considerations: Student unemployed? Do they have daycare expenses? Where do they live? Internet/computer costs Aggregate borrowing: sustainable? Institutional considerations: Distance learners must be treated same way as traditional learners COA must be same for all students in same program Room and board component should be adjusted for less than half time enrolled students

21. COA Resources College Board IPEDS NASFAA Tools EASFAA Peers Survey Monkey

22. F RAUD

23. OIG Audit Findings: Colleges disbursed $222 million in aid to more than 42,000 online students who did not earn credits during a payment period Fraud

24. OIG’s IPAR: Distance Education Fraud Rings L42L0001 “Education programs that are delivered solely through the Internet present unique opportunities for fraud and challenges for oversight, because Title IV programs were designed to deliver aid to students who are physically present in traditional classrooms, rather than alternative on-line environments” Fraud

25. Distance Education Programs growing quickly Verification of Identity is not required Refunds Fraud Challenges

26. Verification of Student Identity Aligning disbursement/refund schedule with add/drop schedule NSLDS and CPS flags for potential fraud activity Monitor classroom activity Fraud Solutions

27. Shared Experiences Other Challenges Questions? Shared Experiences Other Challenges Questions? Melody DeFlorio mdeflori@norwich.edu 802-485-2019