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«FINAL AUDIT REPORT ED-OIG/A07L0001 February 2014 Our mission is to promote the U.S. Department of Education efficiency, effectiveness, and Office of ...»

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Faculty members were also responsible for determining whether a student (1) began attending a course, (2) stopped attending a course, or (3) completed a course. Kent State’s guidelines suggested that faculty members give a grade of “NF” (never attended, counts as an F grade) to those students who never attended a course and a grade of “SF” (stopped attending, counts as an Final Audit Report ED-OIG/A07L0001 Page 53 of 83 F grade) to those students who unofficially withdrew from a course. The SF grade was not to be used after the course withdrawal deadline. After that time, grades were to be based on student performance in completing the course requirements. However, Kent State only encouraged, not required, faculty members to follow the guidelines related to the grades.

Kent State was not required to take attendance. However, if a faculty member provided a last date of attendance for a student who unofficially withdrew, then Kent State used the last date of attendance as the student’s withdrawal date for the return of Title IV aid calculation. Otherwise, Kent State used the midpoint of the payment period as the student’s withdrawal date.

Records Retention Kent State’s higher education software was the repository for official student records. The higher education software contained all students’ official financial aid and academic records, including grades, registration information, and financial aid awards and disbursements.

According to the senior associate provost, Kent State’s policy was to rely on the information that faculty members entered in the higher education software as evidence of a student’s activity or performance in a course. The senior associate provost informed us that communication between a faculty member and a student could take many forms. Therefore, the OIG’s reliance on Kent State’s online learning management system records as the sole evidence of faculty member and student communication was erroneous.

We reviewed data from both Kent State’s higher education software and its online learning management system. Data in Kent State’s online learning management system included activity logs that recorded students’ activities in their distance education courses. Therefore, we expected data related to academic attendance recorded in the online learning management system or other records to confirm that the data that faculty members entered in the higher education software were accurate and complete for students enrolled in distance education courses.

However, the records did not always confirm the information in the higher education software.

For example, of the 50 students whose records we reviewed, 8 students received F grades even though the online learning management system or other records did not contain any evidence of academic attendance. According to Kent State’s policy, those students should have received a grade of NF. We also identified two students who were given SF grades even though the online learning management system or other records did not contain evidence of the students’ academic attendance. Those students also should have received grades of NF. Kent State did not have records to support the grade designations that faculty members entered in its higher education software for any of the nine students. 18 We concluded that the data from the higher education software were not sufficiently reliable for our purposes. Our conclusion was based on Kent State not having records to support the data that faculty members entered in the higher education software. Therefore, instead of relying on faculty-entered data in the higher education software, we used data from the online learning management system to determine whether students attended courses, never attended courses, stopped attending courses, or withdrew from courses, as well as to determine the last date of attendance for students who unofficially withdrew from courses. If we could not find sufficient One student erroneously received an F grade and an SF grade in two separate courses.

Final Audit Report ED-OIG/A07L0001 Page 54 of 83 evidence of academic attendance in the online learning management system, we asked Kent State for any records maintained outside of the online learning system that might be evidence of academic attendance. Kent State did not provide us any such records.

Kent State stated that its policy is to rely on the information that faculty members enter in the higher education software. Thus, administration of Title IV is based on the information entered by faculty members. Kent State informed us that it understands our comment that information entered into the higher education software was not supported, and it is working to develop and refine delivery methodologies for its online instruction. Kent State expected the final refinements to be concluded during the fall 2013 semester.

Determination of Attendance Affects Compliance With the Title IV Requirements We identified attendance issues that affected Kent State’s compliance with the Title IV requirements in four areas: (1) treatment of Title IV funds when a student withdraws, (2) treatment of Title IV funds when a student does not begin attendance, (3) confirmation of eligibility at the time of disbursement, and (4) recalculation of the Pell award.

Treatment of Title IV Funds When a Student Withdraws Of the 50 students in our sample, 26 withdrew during a payment period. Kent State used a last date of attendance that was not supported by evidence of academically related activity for 1 of the 26 students. In addition, Kent State did not perform return of Title IV aid calculations for 12 of the 26 students. As a result, Kent State returned $9,731 less than it should have returned for 6 of the 13 students.





Kent State’s higher education software showed that 5 of the 12 students received F grades in their courses. However, we reviewed each student’s academically related activity as recorded in the online learning management system and concluded that the five students unofficially withdrew from their courses and did not earn their F grades. Using information recorded in the online learning management system, we concluded that the remaining seven students attended enough of the payment period before withdrawing from Kent State to earn 100 percent of the Title IV funds disbursed for the payment period.

Kent State disagreed that it used a last date of attendance that was not supported by evidence of academically related activity for one of the students in the sample. Kent State stated that it used the student’s official withdrawal date as recorded in its higher education software. Kent State further stated that all five students with F grades recorded in the higher education software received a grade in at least one of their courses. Therefore, in accordance with the “2010–2011 Federal Student Aid Handbook,” Volume 5, Chapter 2, page 5–77, Kent State presumed that the student completed the course and thus completed the payment period. In Kent State’s opinion, no returns of Title IV aid calculations were required for any of these five students.

We disagree with Kent State’s position. The one student who officially withdrew was enrolled in three courses. The online learning management system showed that the student had academically related activity in only one of the three courses. The student first officially withdrew from one course in which the student had academically related activity. The student then officially withdrew from the remaining two courses but did not have any academically Final Audit Report ED-OIG/A07L0001 Page 55 of 83 related activity in either course. Kent State should have used the student’s first official withdrawal date when determining the amount to return to the Title IV programs. Instead, Kent State used the later date, the one that was not supported by any academically related activity.

We also disagree that Kent State could presume that a student completed a course just because the student received an F grade. Kent State’s online learning management system showed that all five students either withdrew from school or did not have any academically related activity in their courses. The “2010–2011 Federal Student Aid Handbook,” Volume 5, Chapter 2, page 5–77, states If a student earns a passing grade in one or more of his or her classes offered over an entire period, for that class, an institution may presume that the student completed the course and thus completed the period. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the institution must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period.

Kent State should not have presumed that students who received F grades had completed those courses. It should have assumed the student had unofficially withdrawn.

Treatment of Title IV Funds When a Student Does Not Begin Attending Classes Of the 50 students in our sample, Kent State did not return $45,922 in Title IV funds that it credited to the accounts of or disbursed directly to 12 students without evidence of the students’ attendance in academically related activities during the payment period.

Kent State stated that the financial aid awards recorded in its higher education software for all 12 students were consistent with the number of credit hours in which the students were enrolled at the time of the disbursements. Kent State believed that it made any required adjustments to the students’ Title IV aid after the Title IV disbursements were made.

We disagree with Kent State’s position. We reviewed Kent State’s online learning management system for evidence of academically related activity for all 12 students. We did not identify any academically related activities during the payment period for those 12 students, and Kent State did not provide any other records showing that the 12 students engaged in academically related activity as required by 34 C.F.R. § 668.22(c)(3).

Confirmation of Eligibility at the Time of Disbursement The records for 14 of the 50 students in our sample indicated that the students received Title IV disbursements after the start of the payment period. Kent State disbursed $30,045 to 5 of the 14 students without evidence of the students’ attendance in academically related activities before the disbursement.

–  –  –

We disagree with Kent State’s position. Kent State may use a student’s enrollment status to determine a student’s eligibility for Title IV funds that it disburses before the start of the payment period. However, for Title IV funds that it disburses during the payment period, Kent State is required to confirm that the student engaged in academically related activity in the payment period before it makes the disbursement. Kent State’s online learning management system did not contain evidence that any of the five students engaged in academically related activity as required by 34 C.F.R. § 668.22(c)(3) before the disbursements.

Recalculation of Pell Awards Of the 50 students in our sample, Kent State’s online learning management system records for 23 students indicated a change in enrollment status based on the students’ lack of academically related activity in 1 or more of their classes. The enrollment status changes for 16 of the 23 students had an effect on their Pell eligibility. However, Kent State did not recalculate the Pell awards for those 16 students. As a result, Kent State awarded $11,405 more than it should have awarded to 14 students. The other two students’ Pell awards were not affected by their changes in enrollment statuses.

Kent State informed us that it determined a student’s enrollment status for the semester at the end of the 100 percent tuition refund period (also known as the census date). For the fall and spring semesters, the census date occurred after the first week of the semester. Kent State calculated students’ Pell awards based on a student’s enrollment status as of the census date.

The initial Pell awards for 10 of the 14 students were consistent with the students’ credit hours as of the census date. Therefore, no Pell recalculations were required. For 1 of the 14 students, Kent State stated that the student was registered for 10 credit hours as of the census date, but the student later received an NF grade in one course and dropped a second course before starting it.

Kent State stated that it recalculated the Pell award based on the student’s enrollment in 6 credit hours and reduced the student’s Pell award to reflect half-time enrollment. The remaining three students dropped courses before they started them or received NF grades in courses, but the students’ enrollment statuses were not affected. Therefore, a Pell award recalculation was not required.

We disagree with Kent State’s position. We reviewed Kent State’s online learning management system for evidence of academically related activity for the 14 students. The online learning management system showed that the students did not engage in academically related activity in one or more classes during the payment period. Though Kent State provided a written explanation of its position regarding the 14 students’ Pell awards, it did not provide any other evidence to support that the students’ Pell awards were based on their enrollment statuses in courses for which they had attendance in academically related activities as required by 34 C.F.R.

§ 668.22(c)(3).

Final Audit Report ED-OIG/A07L0001 Page 57 of 83 Appendix E: Ivy Tech Community College of Indiana 2-year public school Ivy Tech was established in 1963 and is headquartered in Indianapolis, Indiana. The school is accredited by The Higher Learning Commission. Ivy Tech offers 12 degree programs and about 350 individual courses entirely through distance education. During award year 2010–2011, Ivy Tech disbursed more than $629 million to about 94,000 students, including about 9,400 students who were enrolled solely in distance education courses.

Cost of Attendance Ivy Tech’s cost of attendance budget includes tuition and fees and allowances for room and board, books, transportation, and personal expenses. Ivy Tech did not create a separate cost of attendance budget for distance education students.



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