1. Attendance in Online Courses Draft Resolution

2. Definition and documentation of attendance in fully online courses significantly impacts students with financial aid When a student receiving Title IV grants and loans withdraws from a program, the student’s institution must determine the amount of assistance the student earned to calculate the amount of unearned funds that must be returned to the Department of Education Background ProblemSolution

3. There is increased oversight of federal student aid for distance education programs by U.S. Department of Education U.S. Department of Education is scrutinizing “last day of attendance” calculations for financial aid students who unofficially withdraw or drop-out from their online courses “Last day of attendance” is used to determine the amount of aid a student is eligible to receive when he/she withdraws or leaves a course ProblemSolution Background

4. Victims of online financial-aid fraud in 2009* – Axia College at University of Phoenix – Lansing Community College in Michigan – Dallas County Community College in Texas – Rio Salado College in Arizona *According to the Inspector General’s report to Congress ProblemSolution Background

5. Anatomy of an Online-Education Scam Anatomy of an Online-Education Scam

6. Office of Federal Student Aid to increase program reviews of student-aid operations next year by 50% Audit-like examinations of student-aid operations designed to ensure that - Students receive only the grants and loans they are entitled to Institutions make refunds in accordance with the law in cases where students withdraw ProblemSolution Background

7. Baker College audited by U.S. Dept. of Education College did not maintain records that were adequate to support its determination of student attendance during 2006-2007 College incorrectly identified when distance education students began and ceased attendance Result Baker College was required to reimburse the U.S. Government thousands of dollars in financial aid funds for errors found and is subject to additional audits to verify the first day of attendance for these students ProblemSolution Background

8. Dept of Ed recommends: – Develop and implement written policy and procedures for attendance Policy and procedures should address maintenance of records adequate to support student eligibility for financial aid – Ensure that the specific date is documented and retained in accordance with the record retention requirements in those cases where the institution has chosen to use the last date of academic activity as the last date of attendance ProblemSolution Background

9. There is no standard measurable definition of "last day of attendance" for fully online courses at Foothill College must document student’s Last Day of Attendance in an “academically related activity” US Department of Education may no longer accept last login as sufficient for the definition of "last day of attendance" for the purposes of federal financial aid Student-tracking is NOT sufficient for defining attendance for purposes of financial aid Background Problem Solution

10. Develop a college policy and/or definition to establish more accurate attendance record-keeping for online courses Advantages to clearly defining and reporting attendance in on-line courses include: Reduce federal and state audit liabilities/exceptions (compliance, enrollment status, benefits receipt) for financial aid recipients Reduce amount financial aid recipients must repay to federal agencies Reduce amount Foothill College must pay for financial aid recipients to federal agencies BackgroundProblemSolution

11. Attendance must be based on student’s Last Day of Attendance in a documented “academically related activity” Acceptable – Meaningful participation in an online discussion – Student initiating contact with a faculty member to ask a course-related question via email or chat room – Quizzes, tests, assignment submission Unacceptable – Student-tracking of course site login – Student posting of bio in Discussion forum BackgroundProblem Solution

12. Foothill Faculty Senate DRAFT Resolution Student Attendance in Online Classes In compliance with federal requirements to document student attendance in online classes, faculty must record a weekly academically related activity such as discussion forum posting, online quiz, reflection, assignment, exam, email, field trip, telephone call or electronic communication at least through week 7 or the drop with “W” deadline for each student in an online class. This is in line with our commitment to best practices of “Regular, Timely and Effective Student/Faculty Contact” as approved by the Faculty Senate and submitted by faculty on the "Course Approval Application for Online/Distance Learning Delivery" and vital to students receiving financial aid.