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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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Billings and Disbursements Ivy Tech is a term-based school, operating on a semester system and charging tuition and fees by semester. Ivy Tech started a new semester each fall, spring, and summer. The fall and spring semesters were 16 weeks. A summer semester could be either 8 or 10 weeks. Ivy Tech also offered “part of term” courses (modules) that were 6 or 8 weeks. Ivy Tech established the payment period as the start date and end date of the students’ courses within the semester.

Therefore, if a student was enrolled only in a 6-week module during a 16-week semester, the student’s payment period would be 6 weeks, not 16.

Ivy Tech disbursed Title IV funds 4 weeks after the start of the semester, programming its higher education software to disburse Title IV funds only if the student met all disbursement requirements, such as making satisfactory academic progress and being enrolled in an eligible program of study.

Attendance and Withdrawal Policies Ivy Tech determined a student’s enrollment status at the end of the second week of the semester (referred to as census date, no-show date, and 100-percent-refund date). For distance education students, Ivy Tech’s attendance policy was that faculty members were required to identify the students who never attended a course by the end of the census date. Faculty members were to administratively withdraw such students with the code of “NW,” indicating that the students did not attend their courses before the census date.

For the purpose of documenting eligibility for Title IV funds, Ivy Tech required students in distance education courses to make at least one academically related contact with the faculty member before the census date. Otherwise, the student would be removed from the course.

Ivy Tech defined an academically related contact as submitting an assignment, responding to a discussion question, or otherwise performing some kind of activity that could be documented and demonstrated active involvement in the course.

Ivy Tech did not have policies or procedures that established what activities could or could not be considered evidence of academically related activity for distance education students after the census date. After the census date, faculty members were responsible for maintaining attendance Final Audit Report ED-OIG/A07L0001 Page 58 of 83 records. Each faculty member was responsible for determining what types of activities would be considered evidence of attendance. Faculty members were responsible for determining whether a student (1) began attending a course, (2) stopped attending a course, or (3) completed a course.

Ivy Tech’s policy was that faculty members were to assign a grade of “FW” to students who failed to achieve a course objective because they stopped attending classes and did not officially withdraw.

Though Ivy Tech was not required to take attendance, before spring 2012, Ivy Tech used the last date of attendance as the withdrawal date for return of Title IV aid calculations if a student completed more than 50 percent of the payment period. Otherwise, Ivy Tech used the midpoint of the payment period as the withdrawal date. Effective spring 2012, Ivy Tech began to use the midpoint of the payment period for all return of Title IV aid calculations.

Determination of Attendance Affects Compliance With the Title IV Requirements We identified attendance issues that affected Ivy Tech’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, 40 withdrew during a payment period. Ivy Tech used an unsupported last date of attendance or did not perform return of Title IV aid calculations for 21 students, resulting in Ivy Tech returning $7,538 less than it should have for 10 students.

Ivy Tech used a last date of attendance that was not supported by evidence of academically related activity for 6 of the 21 students. In addition, Ivy Tech did not perform return of Title IV aid calculations for 15 of the 21 students. After reviewing information recorded in Ivy Tech’s online learning management system, we concluded that 6 of the 21 students attended enough of the payment period before withdrawing from school to earn 100 percent of the Title IV funds disbursed for the payment period. We did not identify a financial impact for five of the students.

Ivy Tech disagreed that it returned less than it should have for the 10 students. According to Ivy Tech, eight students completed the term and did not require a return of Title IV aid calculation. Although these students received F grades in their courses, the F grades were earned. Ivy Tech explained that it had a unique grade designation, FW, for students who failed the course because they ceased attending (unofficial withdrawal). The F grade for these eight students indicated that they continued attending their courses and failed because they did not comprehend the material or pass the academic requirements for the course. Ivy Tech stated that the other two students attended beyond the 60 percent point in the payment period, and supporting documentation of the students’ participation in academically related activities was maintained. In Ivy Tech’s opinion, schools were not required to perform return of Title IV aid calculations if a student attended beyond the 60 percent point of the payment period.





We disagree with Ivy Tech’s position. For the eight students who Ivy Tech claimed earned their F grades, the online learning management system did not contain evidence of academically related activity showing that the students attended their courses long enough to earn the F grades.

Final Audit Report ED-OIG/A07L0001 Page 59 of 83 Therefore, we used the last date of academically related activity in the payment period to perform return of Title IV aid calculations. Using last dates of attendance supported by academically related activity in the online learning management system, we determined that the other two students did not attend more than 60 percent of the payment period and a return of Title IV aid calculation was required.

Treatment of Title IV Funds When a Student Does Not Begin Attending Classes Of the 50 students in our sample, Ivy Tech did not return $3,766 in Title IV funds that it credited to the accounts of or disbursed directly to 2 students without evidence of the students’ attendance in academically related activities during the payment period.

Ivy Tech stated that both students received an FW grade, indicating that the students started the term, but stopped attending their courses at some point. Ivy Tech stated it is the school’s policy that faculty members notify the registrar’s office when a student does not attend a class session or show participation in an academically related activity during the first 2 weeks of the semester.

When that occurred, the faculty members had to administratively withdraw the student from the course using the code NW. Neither of these students’ records contained the NW code, indicating that the students attended during the term.

We disagree with Ivy Tech’s position that the two students started attending their courses during the payment period. We reviewed Ivy Tech’s online learning management system for evidence of academically related activity for the two students. We did not identify any academically related activity for those two students during the payment period, and Ivy Tech did not provide any other evidence showing that the two students engaged in academically related activity as required by 34 C.F.R. § 668.22(c)(3).

Ivy Tech informed us that it implemented a new process starting with the spring 2012 term.

Starting with that term, faculty members receive an automated notification for all students who drop from their courses. The automated email requires faculty members to attest to the students’ attendance or lack of attendance. Ivy Tech stated that this new process should help strengthen its internal control and provide an additional layer of compliance in relation to this issue.

Confirmation of Eligibility at the Time of Disbursement The records for 1 of the 50 students in our sample indicated that Ivy Tech disbursed Title IV funds after the start of the payment period without evidence of the student’s attendance in an academically related activity before the disbursement.

Ivy Tech stated that the student received an FW grade, which indicated the student attended during the term. If the student would have received an NW grade, it would mean that the student did not attend during the term.

We disagree with Ivy Tech’s position that the student began attending courses during the payment period. Ivy Tech’s online learning management system did not contain evidence showing that the student engaged in academically related activity as required by 34 C.F.R.

§ 668.22(c)(3) before or after the disbursement.

Final Audit Report ED-OIG/A07L0001 Page 60 of 83 Recalculation of Pell Awards Of the 50 students in our sample, the online learning management system records for 7 students indicated a change in enrollment status based on the students’ lack of academically related activity in one or more of their courses. The enrollment status changes for five of the seven students had an effect on their Pell eligibility. However, Ivy Tech did not properly recalculate the Pell award for those five students. As a result, Ivy Tech awarded $2,803 more than it should have awarded to the five students.

Ivy Tech stated that the evidence contained in its higher education software supported that, when necessary, Pell awards were adjusted based on changes in student enrollment statuses in conjunction with the school’s census date and no-show policies. For two of the five students, Ivy Tech stated that it properly adjusted the Pell awards to reflect courses that were dropped. For three of the five students, Ivy Tech stated that the Pell awards did not require adjustments because the students attended each course beyond the school’s census date. Ivy Tech provided information from its higher education software to support that it properly adjusted the Pell awards when required.

We disagree with Ivy Tech’s position. We compared the students’ attendance records from the higher education software with information from Ivy Tech’s online learning management system. The online learning management system showed that the five students did not have academically related activity in one or more of their courses.

Final Audit Report ED-OIG/A07L0001 Page 61 of 83 Appendix F: Valencia College 2-year public school Valencia was founded in 1967 as Valencia Junior College and is headquartered in Orlando, Florida. The school is accredited by the Commission on Colleges of the Southern Association of Colleges and Schools. Valencia offers associate and bachelor degree programs, including about 200 individual courses through distance education. During award year 2010–2011, it disbursed more than $173 million in Title IV funds to about 36,000 students, including about 3,200 students who were enrolled solely in distance education courses.

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

Billings and Disbursements Valencia is a term-based school, operating on a semester system and charging tuition and fees by the semester. Valencia established the semester as its payment period. Each semester was 16 weeks, and each course was either 8, 10, or 16 weeks. Valencia started a new semester each fall, spring, and summer.

Valencia usually disbursed Title IV funds during the fourth week of each semester. However, if a student was enrolled in courses that did not all start on the same date, Valencia disbursed Pell funds based on the start date of the latest starting course. Before disbursing Title IV funds, Valencia’s financial aid services office reviewed each student’s records for compliance with Title IV eligibility requirements, such as the student making satisfactory academic progress and not being in default on prior loans.

Attendance and Withdrawal Policies Although Valencia was not required to take attendance, it required its faculty members to monitor their students’ attendance. Valencia’s attendance policy allowed faculty members to set their own attendance policies but required the policies to be documented in the course syllabus.

The policy suggested methods for gauging student attendance in the online environment. For award year 2010-2011, suggested methods included the faculty member requiring evidence of the student (1) logging in to the course, (2) emailing a faculty member, (3) taking an orientation quiz, (4) posting to a discussion board, or (5) completing any assignment that enabled the faculty member to verify the student’s attendance and intention to continue in the course. However, each faculty member ultimately determined what activity would be considered attendance.

Evidence of academic attendance was maintained in either the online learning management system or outside the online learning management system.

Faculty members were required to maintain attendance records for 3 years. Valencia also required faculty members to report students who did not begin attending their courses by the end of the first week of the course. If a student violated the faculty member’s attendance policy, the faculty member could withdraw the student from a course up to the beginning of the final exam period. Faculty members also were required to report each student’s last date of attendance in a course. For students who unofficially withdrew, Valencia used the last date of attendance as the withdrawal date for return of Title IV aid calculations.

Final Audit Report ED-OIG/A07L0001 Page 62 of 83 Beginning in August 2011, Valencia established a policy that no longer considered logging in to an online course to count as activity supporting attendance during the first week of the course.



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