Addressing Unofficial Withdrawals and Federal Financial Aid Compliance Addressing Unofficial Withdrawals and Federal Financial Aid Compliance February 2, 2010 W. Michael George University of Alabama

Background of Federal Financial Aid Rules for Withdrawals Basic expectations of the U.S. Department of Education Documented versus undocumented withdrawal from all courses Comparison with academic rules in place on campuses Relationship to fee refund/forfeiture issues

Basic Federal Expectations for Enrollment of Financial Aid Recipients Attendance – Student must actually attend to be eligible for federal student aid. – Generally, the institution is liable if the student fails to attend. Completion – Student must complete payment period for which aid was awarded, or – The institution must return a prorated amount of the aid if withdrawal occurs prior to completion of 60% of the term.

Documented Versus Undocumented Withdrawal from All Courses Return of Title IV Aid (R2T4) requires – Either: » Official withdrawal date » Unofficial withdrawal date – Date of last attendance

Comparison with Academic Rules in Place on Campuses No federal requirement that rules fit together – Student service, clear information suggest best if the rules make sense – May have fiscal impact – Rules are often a stated faculty policy

Relationship to Fee Refund/Forfeiture Rules If possible, similar rules are helpful – Calculations are already complex – Academic advisors, faculty, and others engage in advising student about academic withdrawal, so simplicity helps with compliance

Changes from Prior Rules Compared to environment prior to Return of Title IV Aid rules, changes have resulted from – Findings and penalties in federal audits – Challenges presented by the new expectations of monitoring attendance

Challenges Presented by New Expectations Monitoring attendance at large campuses – Applying Return of Title IV (R2T4) rules » In timely fashion » Unifying all coursework for students with unofficial withdrawals

Pros and Cons of Institutional Options to Federal Compliance Taking attendance on a regular basis Monitoring enrollment during the course of a term Monitoring enrollment after the term is completed Determinants in choosing among these options

Taking attendance on a regular basis Pros – Most straightforward way to meet requirements – Allows feedback from faculty about true attendance patterns Cons – Difficult to implement if not already part of the faculty culture – Extensive data gathering and comparison across students’ courses

Monitoring enrollment during the course of a term Pros – One-time reporting is simpler for faculty – Provides feedback in time for changing aid prior to next term Cons – Unless part of existing mid-term grading, adds a reporting requirement for faculty – Adds Registrar and Financial Aid staff pressure for quick turn around that may conflict with other priorities

Monitoring enrollment after the term is completed Pros – Less subject to change – Fits with standard faculty reporting Cons – Occurs after enrollment for subsequent term » Billing may hold up enrollment – No time for change in student behavior

Determinants in choosing among these options Academic Calendar – Length of term may be most significant Size of Institution Prior procedures related to campus retention efforts

Role of Faculty in Unofficial Withdrawal Process Must keep track of students who stop attending, for example – Last evidence of work submitted – Last exam – Non attendance at labs or small group sessions Different approaches may yield different assessment of lack of student attendance – Incomplete – Failure – Dropped out

Developing and Deciding on a Proposed Solution Collaborate

Implemethe Solution Implemented Spring 2009 Discussion with faculty groups to faculty about new grade Alignment with web-based grading Description on web grade roster reminder prior to grading period

New Grades: NA and DO Definition – A “NA” grade denotes that the student has never attended any meeting time for the course – A “DO” grade denote that the student attended at least one or more meeting times for the course

NA-DO Grade Rationale: Creation and reporting of these new grades and the date the student stopped attending is the “remedy” chosen by the university to avoid a current or future multi- million $ fine being levied against UA by the Federal Government because we are not documenting the last recorded date of class attendance. The alternative was keeping daily attendance. This documentation requirement is mandated by Federal Student Financial Aid Regulations.

Managing the Solution Actions of the Accounts Receivable Actions of the Office of the University Registrar

Specific actions in the Accounts Receivable Office in response to the process Divided students into 4 categories: – Those who received Title IV aid, and have ALL NA/DO grades » Treated like total withdrawal students » Aid evaluated for potential return of Title IV funds » Accounts Receivable conducts this analysis

Specific actions in the Accounts Receivable Office in response to the process (con’t) – Those who received Title IV aid, and have one or more NA/DO grades and otherwise all dropped courses » Aid evaluated for potential return of Title IV funds » Accounts Receivable conducts this analysis

Specific actions in the Accounts Receivable Office – Students who received Title IV aid, and have a combination of NA/DO grades and successful marks » Aid evaluated for potential return of Title IV funds » Accounts Receivable conducts this analysis – Students who received Title IV aid, and have ALL “unsuccessful” marks » “Unsuccessful” marks: missing grades » Additional information is needed from instructors » With additional information, review for any potential return of Title IV aid » Accounts Receivable conducts this analysis

Specific actions of the University Registrar – Weekly Reports

Contact Information Michael George University Registrar University of Alabama