Federal Title IV and Last Day of Attendance

Background

Several online programs have been targeted by financial aid fraud schemes in which a "student" registers for an online class, logs in, then drops the class after financial aid funds have been disbursed. Because of this, federal Title IV guidelines are aimed at preventing financial aid fraud in distance education courses. 

A "Dear Colleague" letter from the Department of Education in October 2011 called upon post-secondary distance education programs to put more stringent measures into place to make sure that students are not just enrolled in courses, but also actively participating in them. The department expects "institutions to take steps necessary to ensure that students are academically engaged prior to disbursing Title IV student aid funds. If students do not begin attendance, Title IV funds must be returned." (34 CFR 668.21(a))

Requirement

Faculty are required to report the last day of attendance (LDA) for students who have withdrawn from a class or who never attended. It is not enough to evaluate a student’s attendance based solely on the number and frequency of logins or through course statistics in Canvas. The federal guidelines are meant to protect the institution from students who are receiving financial aid assistance but who are not participating in class. Instructors must drop students based on their participation in class. "Attendance" through logins is not the same as participation, in which the student is academically engaged. Participation means actively completing course activities, such as assignments, assessments, posting to discussion boards, etc. 

Distance education instructors are advised to follow LPC's withdrawal policy for dropping student from DE courses. You should make the policy clear in your welcome letter and in your syllabus.

Aside from meeting compliance with Title IV, noting the LDA can potentially save students money they have to repay the college if they drop. This allows the Financial Aid office to know the exact date, as opposed to an approximate date.

Noting the LDA in Canvas

Once students are officially dropped from a course after Census, they will be made inactive in that Canvas course, and all of their work will disappear. If you are asked to check their participation for financial aid reasons, you can do 1 of 2 things:

1. Go to the gradebook, and choose to show inactive enrollments. This will make the student's work reappear. Go to the last assignment in which the student participated, and note the date of submission.
2. Alternatively, go to the People page in your course, click on the three dots on the right side for the student (who is already marked as inactive), and select User Details. Choose Access Report from User Details and view the last day a student participated in the course by checking the date next to an assignment (signified by a number in the Times Participated column).

When you know the student's last day of attendance, go to People - the three dots - User Details. This brings you to the student’s Profile page. Simply enter the date in the box under Last Day Attended. 

If a student dropped prior to Census, you can't enter the student's LDA into Canvas because that student simply disappears from the course. The best you can do is note the date elsewhere after monitoring your class roster in CLASS-Web. If you are so inclined, you can keep a log of what work he might have completed and when he quit actively participating in the class. 

Notes About Dropping Students

Here are some suggestions:

• In the event of an audit or accreditation request, make sure you always use the Canvas Inbox for email communication with students. Canvas saves all emails here, which makes it convenient if you need to reference communications.
• Download your gradebook just prior to Census. Better yet, download it every couple of days until Census in order to get a record of all student work up to that point.
• You might want to consider creating a "Check In" discussion forum and require students to participate in the forum prior to a specific day early in the course: Day 3, for example. 
• You can also require students who wish to stay enrolled to complete ALL assignments in the first module by a specific due date.
• Should you drop a student by mistake, or should a student successfully challenge a drop, that student needs to officially re-enroll back into the course. All of her work will reappear.