Addressing UnofficialAddressing UnofficialWithdrawals and FederalWithdrawals and FederalFinancial Aid ComplianceFinancial Aid ComplianceFebruary 2, 2010

W. Michael GeorgeUniversity 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<OR>» Unofficial withdrawal date<AND>

– 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• E-mail to faculty about new grade• Alignment with web-based grading• Description on web grade roster• E-mail 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 GeorgeUniversity RegistrarUniversity of Alabamamichael.george@ua.edu205-348-2857