Executive Policy 7.209 Executive Policy 7.209

Student Participation Verification in Coursework

Executive Policy Chapter  7, Student Affairs
Executive Policy 7.209, Student Participation Verification in Coursework
Effective Date:  July 2020
Prior Dates Amended:  None
Responsible Office: Office of the Vice President for Academic Planning and Policy
Governing Board of Regents Policy: None
Review Date:  July 2023

1. Ensure institutional administrative capability and compliance with Federal Student aid (FSA) Title IV financial aid regulations regarding verification of students’ initial attendance in post-secondary coursework.  Standards of administrative capability require that institutions maintain adequate records for each FSA recipient.  Students may become FSA recipients at any time.  Records must clearly show that the student was eligible for the funds received and that the funds were disbursed in accordance with program regulations.  This includes being able to confirm initial attendance of students:
   
   1. Students with Federal Direct Loans are not eligible for the loan unless the institution can confirm the student began attendance in enough courses to establish at least a half-time enrollment.
   
   
   2. For Federal Pell Grant, FSEOG, and Work Study recipients, if the student does not begin attendance in all of his or her classes, resulting in a change in the student’s enrollment status, the institution must recalculate the student’s award based on the lower enrollment status within a specified period of time.
   
   
   3. If a school disburses Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, Perkins Loan, or FSEOG funds, but the student never begins attending classes, an institution must return the disbursed funds to their programs
   
   
   4. For students in distance education courses, A determination that the student began attendance by participating in an academically-related activity must be made by the institution; a student's certification of attendance that is not supported by institutional documentation is not acceptable. 
   
   
2. Maintain accurate institutional records regarding student enrollment for federal reporting.  Required reporting includes students’ academic program information and accurate enrollment status.


3. Consequences for non-compliance include discontinuation of financial aid monies for the campus for awarding to students.

1. Participation verification is the term used to document when a student is present at an academically related activity in a course by the late registration deadline.
   
   Presence includes, but is not limited to:
   
   1. Physically attending a class where there is an opportunity for direct interaction between the instructor and students;
   
   
   2. Submitting an academic assignment;
   
   
   3. Taking an exam, an interactive tutorial, or computer-assisted instruction;
   
   
   4. Attending a study group that is assigned by the institution;
   
   
   5. Participating in an online discussion about academic matters; and
   
   
   6. Initiating contact with a faculty member to ask a question about the academic subject studied in the course; and
   
   Presence does not include activities where a student may be present, but not academically engaged, such as—
   
   1. Living in institutional housing;
   
   
   2. Participating in the institution's meal plan;
   
   
   3. Logging into an online class without active participation; or
   
   
   4. Participating in academic counseling or advisement.
   
   A determination of “academic attendance” or “attendance at an academically-related activity” must be made by the institution; a student's certification of attendance that is not supported by institutional documentation is not acceptable.
   
   
2. Delinquent Financial Obligation - Past due on a financial obligation of the University of Hawai‘i, or failing to pay for tuition and fees by a published deadline (AP 8.621).

Attendance and class participation are both a privilege and an obligation.  They are factors that promote college success.  Students are expected to establish initial attendance and maintain consistent attendance and participate in the courses for which they are registered.  

Some students within the UH System enroll in classes, have tuition and fees payment balances, but fail to follow through with course attendance and completion (“no show”).  Currently, these students accrue a bill based on registration, regardless of attendance.  This financial obligation can prevent them from further enrollment when they are ready to succeed.  Moreover, this process creates a burden of collection on the College’s business office and is a risk regarding institutional compliance.  

This policy functions to underscore the importance of the first days as a foundation for semester success, to prevent unnecessary financial obligations for students who have not reaped educational benefit due to nonattendance in a course, and to keep the institution in compliance with Federal Title IV funding rules and regulations.

Under this policy, students who fail to establish attendance and participation in class by the end of the late registration period (“no show”) are dropped from the class.  Tuition and fees charges for the class will be deleted from the student’s account and, if applicable, the student’s financial aid or veteran’s benefits will be recalculated accordingly.  The class will be erased from the transcript and no grade will be assigned.

In order to implement this policy, all faculty members must verify initial participation of students registered in their courses by the end of the late registration period for that term.  Faculty members teaching online, hybrid, or other classes that do not meet face-to-face during the late registration period will verify initial attendance through one of the following ways:
           

1. Submission of an academic assignment


2. Completion of an assessment


3. Participation in an online discussion board about academic-related topics


4. Completion of a trackable interaction within the learning system


5. Email the faculty member about a course-related subject


6. Other academically-related activity defined by the faculty member that meets federal guidelines for establishing initial attendance.

A student is responsible for informing the faculty member if he/she will be absent during the late registration period and wishes to stay enrolled.

A student who is dropped from a course via this policy may request a reinstatement in the course through the Vice Chancellor for Academic Affairs (VCAA) to add back a dropped course with instructor permission.  Late fees may apply.  Students who are reinstated are responsible for any missed work.

There is no policy-specific delegation of authority.

Office of the Vice President for Academic Planning and Policy
(808) 956-6897 | ovpaa@hawaii.edu | www.hawaii.edu/offices/vp-academic-planning-policy

1. Students with Federal Direct Loans are not eligible for the loan unless the institution can confirm the student began attendance in enough courses to establish at least a half-time enrollment: 34 C.F.R. §685.303; https://www.govinfo.gov/content/pkg/CFR-2019-title34-vol4/xml/CFR-2019-title34-vol4-sec685-303.xml



2. For Federal Pell Grant, FSEOG, and Work Study recipients, if the student does not begin attendance in all of his or her classes, resulting in a change in the student’s enrollment status, the institution must recalculate the student’s award based on the lower enrollment status within a specified period of time: 34 C.F.R. §690.80; https://www.govinfo.gov/content/pkg/CFR-2019-title34-vol4/xml/CFR-2019-title34-vol4-part690.xml#seqnum690.80



3. If a school disburses Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, Perkins Loan, or FSEOG funds, but the student never begins attending classes, an institution must return the disbursed funds to their programs: 34 C.F.R. §668.21,  34 C.F.R. §674.16,  34 C.F.R. §676.16,   https://www.govinfo.gov/content/pkg/CFR-2014-title34-vol3/pdf/CFR-2014-title34-vol3-sec668-21.pdf,  https://www.govinfo.gov/content/pkg/CFR-2002-title34-vol3/pdf/CFR-2002-title34-vol3-sec674-16.pdf and  https://www.govinfo.gov/content/pkg/CFR-2011-title34-vol3/pdf/CFR-2011-title34-vol3-sec676-16.pdf



4. For students in distance education courses, A determination that the student began attendance by participating in an academically-related activity must be made by the institution; a student's certification of attendance that is not supported by institutional documentation is not acceptable: 34 C.F.R. §668.22;   
   https://www.govregs.com/regulations/expand/title34_chapterVI_part668_subpartB_section668.22

No Exhibits and Appendices found

    President