ONLINE PROGRAMS: CHALLENGES AND

SOLUTIONSMelody DeFlorioMay 18, 3014

• Identify Challenges1

• Discuss institutional solutions2

• Discuss long term ED solutions3

Goals

Distance Education CoursesHEA 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

Distance Education

VERIFICATION

PROCESSING AID

COA

FRAUD

Challenges

• Educational Purpose

• Identity• Citizenship• Unusual enrollment

History

Verification

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.

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

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

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

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

Enrollment Status

Attendance Policy

R2T4

Overpayments

Challenges of Processing Aid

Enrollment status Challenges

Award/Refund Accuracy

Communication

Enrollment status Challenges

Award/refund accuracy

Communication

Registrar

Faculty

Financial Aid

Enrollment

Participation

Eligibility

‘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

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

R2T4 and Overawards

Problem:

• Higher risk of overaward/overpayment

Solutions:

• Routine monitoring of attendance

• Routine monitoring of enrollment status,

particularly for module-based programs

COST OF ATTENDANCE

Tuition and Fees

Books, supplies

Transportation

Miscellaneous

Room and board

Dependent care

Disability care

Loan fees

Exceptional Expenses*

Allowable COA Costs

Allowable COA Costs

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

COA Resources

College Board

IPEDS

NASFAA Tools

EASFAA Peers

Survey Monkey

FRAUD

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

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

• Distance Education Programs growing quickly• Verification of Identity is not required• Refunds

Fraud Challenges

Verification of Student IdentityAligning disbursement/refund schedule with add/drop scheduleNSLDS and CPS flags for potential fraud activityMonitor classroom activity

Fraud Solutions

Shared Experiences

Other Challenges

Questions?

Melody DeFloriomdeflori@norwich.edu802-485-2019