Awarding and Processing Aid for Modular Session Programs

1
Awarding and Processing Aid for Modular Session
Programs

• Pamela Moran and Dan Klock
• U.S. Department of Education

2
Topics

• Awarding Aid for Programs Using Modules
• Disbursing Aid for Programs Using Modules
• Handling Intersessions
• R2T4 Regulations Affecting Modules

3

• Awarding and Disbursing Aid for Programs Using
  Modules

4
Use of ModulesChanging Patterns in Education

• Short term and sequential course enrollment
• Courses are often offered in modules (usually 1-8
  weeks in length)
• Programs with modules may -
• compose an entire program or
• be offered in conjunction with other full-term
  length courses

5
Use of ModulesChanging Patterns in Education

• Used in Standard and Non-Standard Term and
  Non-Term Settings
• Sometimes involve overlapping terms
• Courses offered as modules may begin in one term
  and end in another term
• Enrollment can begin at beginning of any module
• Students may skip one or more modules

6
Basics Term

• A term
• Defined as a discrete period of time during which
  all courses are scheduled to begin and end
• Within a term full-length courses, compressed
  courses or modules, and courses offered
  sequentially

7
Basics Standard and Non-Standard Terms

• Standard Term a semester or trimester (generally
  14-17 weeks long) or a quarter (generally 10-12
  weeks long)
• Non-standard Term all coursework begins and ends
  within a set period, but it is not a semester,
  trimester, or quarter

8
Basics Non-Term

• Courses do not all begin and end within a
  discrete period of time and may
• - contain self-paced or independent study
  courses without fixed timeframes
• - consist of sequential modules or courses that
  do not begin and end within a term
• Clock-hour programs are always non-term

9
Other Title IV Factors

• Definitions
• Academic year 30 (credit hours) or 26 weeks
  (clock hours) of instructional time, and for
  undergraduates 24 semester/trimester hours, 36
  quarter credits, or 900 clock hours for
  graduates, institutional minimum full-time
  standard
• Full-time greater than statutory minimum or
  adjusted for summer or intersession?

10
Modules - Operating Principles

• Schools may combine a series of modules into a
  single term
• Enrollment can begin at beginning of any module
• Students may skip one or more modules within the
  term
• Loan period includes entire term

11
Modules - Operating Principles

• Up-front enrollment (registered courses) should
  support aid eligibility and award amount
• Cost of attendance excludes periods of
  non-attendance
• Student must begin attendance in all credits or
  recalculation required (except loans)

12
Module - Operating Principles

• For loans, student must commence attendance or is
  ineligible borrower for entire term
• No disbursement can be scheduled during period of
  non-enrollment
• Earliest attendance dictates first disbursement
  payment period begins with module that includes
  first date of attendance

13
Modules - Operating Principles

• Change in enrollment status to less-than-half-time
  results in cancellation of subsequent loan
  disbursements.

14
Modules - Operating Principles within a Standard
Term or Substantially Equal Non-Standard Term of
at Least Nine Weeks

• Pell Formula 1 applies
• Standard Term loan disbursement and annual loan
  limit progression applies
• Warning Structure of modular terms can transform
  standard term program into non-standard term
  module begin/end date must be within 2 weeks of
  duration of standard term (Ex 2 3)

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ModulesCommon Term Configurations

• Example 1 - A series of modules within a
  standard 16-week term

Semester- 16 Weeks/ 12 cr.
Module I- Module II-
Module III- Module IV- Four
Weeks /3 cr. Four Weeks/3 cr. Four Weeks/3
cr. Four Weeks/ 3cr.
Module 1
Module 2
Eight Weeks - 6 cr.
Eight Weeks 6 cr.
16
ModulesCommon Term Configurations
Example 2 - A standard term with several
concurrent and overlapping modules

Semester- 16 Weeks/12 cr.
Module I- Module II- Module III- 6
Wks/ 5 cr. 4 Wks/ 3 cr. 6 Wks/ 4 cr.
Module IV- Beginning at 4Wks/ 3cr.
Module V- 4 Wks/3 cr.
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ModulesCommon Term Configurations

• Example 3
• A 16-week standard term with three modules
  offered concurrently module begin and/or end
  dates within two weeks of standard terms duration

Semester-16 Weeks/ 12 cr.
Module I- 6Wks/4cr. Module II- 6Wks/4cr.
Module III-6Wks/4cr.
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Example 1 Standard Term

• Student enrolls in I, II, IV 3-credit hour
  modules
• Student enrolls in 2nd 8-credit hour module only
• - adjust the COA downward to reflect the costs
  of the actual period of enrollment
• - loan period is entire semester

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Example 1- Standard Term

• - low cohort default rate school single
  disbursement for the term scheduled for actual
  attendance otherwise multiple disbursement
  with 2nd disb. at calendar midpoint of term
• - if no enrollment in 3 cr. Module III, 2nd
  disb. not at calendar midpoint
• - Pell and campus-based payment period is term
  recalc. required if no attendance in all
  registered classes

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Examples 2 and 3 Standard Term

• Module duration within 2 weeks of semesters
  duration, therefore standard term treatment
  maintained
• Pell Formula 1 applies
• Total enrollment in all modules, including
  overlapping modules used to determine COA if
  student registered for all modules

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Example 4 - Non-Standard Terms
8 weeks 10 weeks 9 weeks 9 weeks 9 weeks 10 weeks 3 weeks
6 cr 9 cr 3 cr 3 cr 3 cr 9 cr 3 cr
Term Term Term Term Term Term Term
Start Week Week Week Week
date 8 18 27 37
2nd Loan Disbursement

• Academic Calendar 36 semester credits over 40
  weeks of instructional time
• Title IV academic year 24 semester credits and
  30 weeks of instructional time

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Example 4- Non-Substantially Equal Non-Standard
Term

• Pell Grant Formula 3 applies
• Term Payment Period for Pell and Campus-Based
• Minimum BBAY loan period 36cr/37wks
• Loan must be multiply disbursed 2nd Disbursement
  after completion of 18 credits and 21
  instructional weeks

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Example 4 Non-Substantially Equal Non-Standard
Term

• Calculation of Full-Time Enrollment Status for
  each payment period
• of credit hrs. in academic year
• X
• wks of instruct.time in pay.period
• wks of instruct.time in acad. year

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Example 4- Non-Substantially Equal Non-Standard
Term

• Pell Grant Formula 3 applies
• Term Payment Period for Pell and Campus-Based
• Minimum BBAY loan period 36cr/37wks
• Loan must be multiply disbursed 2nd Disbursement
  after completion of 18 credits and 21
  instructional weeks

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Modules Non-Term ConfigurationExample 5
Non-term Undergrad Cert. Program
5 hrs 5 hrs 5 hrs 5 hrs 5 hrs 5 hrs 10 hrs 10 hrs 10 hrs
5 wks 5 wks 5 wks 5 wks 5 wks 5 wks 8wks 8 wks 8 wks

• Academic Calendar 60 quarter hours over 54 weeks
  of instructional time not self-paced
• Title IV academic year 36 quarter hours and 30
  weeks of instructional time
• Full-time 36 quarter hours over 30 weeks of
  instructional time

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Modules Non-term ConfigurationExample 5
Non-term Undergrad Cert. Program

• Minimum BBAY loan period academic year first
  10-hour module must be included to meet 36 hour
  requirement 40 quarter hours and 38 weeks of
  instructional time
• Loan must be multiply disbursed 2nd
  Disbursement of Loan 1 after completion of 20
  quarter hours and half the weeks of instructional
  time

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Modules Non-term ConfigurationExample 5
Non-term Undergrad Cert. Program

• Second loan period is remaining balance of
  program 20hrs/16 weeks for multiply-disbursed,
  prorated loan amount calculated as 20/36 (hrs in
  loan period over hours in the academic year
• Pell uses Formula 4 and Pell and Campus-Based
  observe same payment periods

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• Handling Intersessions

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Intersessions

• Generally offered at schools using standard terms
  
• May be a short session between two standard terms
  for example, 3 weeks of instructional time
  between two 15-week semesters
• May be a shorter summer term for example, 12
  weeks of instructional time with a 12-semester
  hour full-time standard
• Must offer aid to eligible students in these
  sessions

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Intersessions Applicable Title IV Definitions

• Academic year
• - 30 weeks of instructional time
• - 24 semester hours for undergraduate programs
• Full-time
• - 12 semester hours for semesters and summer
  term
• 3 semester hours for intersession treated as
• separate term
• 3 wks in term X 24 hrs in acad.year
• 30 wks in acad. year 3 hrs (2.4 rnd up)

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Intersession as Separate Term

• Creates Non-Standard Term Environment
• Pell Formula 3
• Direct Loans
• - BBAY only No longer qualifies to use SAY
• - Payment Period and Disbursement for unequal
  terms

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Intersession as Separate Term - Pell

• Payment period calculations vary under Formula 3
• Prorate payments based on weeks in each payment
  period
• -Semesters 15/30 annual award
• -Summer 12/30 annual award
• - Intersession 3/30 annual award

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Intersession as Separate Term Direct Loans

• Loan Period Minimum is lesser of Title IV acad.
  year, program length, or remaining balance of
  acad. year for grad/prof, hours a full-time
  student completes in acad. year No one-term
  loans
• Payment period is non-term disburse at beginning
  and midpoint after completing 1/2 hours and
  instructional weeks
• Annual loan limit progression completion of both
  weeks and hours in the acad. year

34
Intersession Merged with Standard Term

• Pell - Formula 1
• Direct Loans
• - Choice of SAY or BBAY
• - Loan periods, payment periods,
  disbursement, and loan limit progression
  based on standard term, traditional calendar
  treatment

35
Intersession Merged with Standard Term - Pell

• Same payment period calculations for all terms if
  Formula 1 used
• Payments for payment periods same for all terms
  in an award year for particular award year
• Payments (e.g., semester )
• - Semesters ½ annual award
• - Summer ½ annual award
• - Intersession None part of the term

36
Intersession Merged with Standard Term Direct
Loan Requirements

• Loan Period Options
• - SAY with summer as header or trailer
• - Standard Term BBAY
• - one term loan
• Loan Limit Progression after completion of SAY
  or Standard Term BBAY
• Payment Period term, which may include addition
  of intersession
• Disbursement Frequency Next term

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Case Study 1-Treated as Separate Term

• Anticipated Enrollment 12 credits each semester
  3 credits for intersession
• Pell Scheduled Award 4,000 for award year
• Loan Period for DL Fall and Spring
• Non-standard term treatment for loans Pell
  remains by term

38
Case Study 1-Treated as Separate Term

• Students Actual Enrollment
• Fall 1 - 12 credits (drops to 6 before drop/add)
• Intersession 3 credits
• Spring - 6 credits
• Summer 6 credits (fails 3 credits)

39
Case Study 1- Treated as Separate Term Pell
Formula 3

• Fall 1 half-time withdrew before census date
  15/30 X 2,000 1,000
• Intersession full-time
• 3/30 X 4,000 400
• Spring half-time
• 15/30 X 2,000 1,000
• Summer half-time
• 12/30 X 2,000 800

40
Case Study 1 Treated as Separate Term Direct
Loan

• Loan Originated for Fall through Spring (24
  attempted credits over 33 instructional weeks)
• Student must complete credits and instructional
  weeks non-standard term treatment
• Two disbursements 2nd scheduled for Spring

41
Case Study 1 Treated as Separate Term- Direct
Loan

• Due to enrollment changes and non-completion, 2nd
  disbursement rescheduled and loan limit
  progression at completion of following Fall term
  rather than originally anticipated Spring term

42
Case Study 2 Merged with Term

• Anticipated Enrollment 12 credits for Fall and
  15 credits for Spring (includes intersession)
• Pell Scheduled Award 4,000 for award year
• Loan Period Fall and extended Spring (includes
  intersession)

43
Case Study 2 Merged with Term

• Students Actual Enrollment
• Fall 1 12 credit hours (drops 6 before drop/add)
• Intersession 3 credits (toward Spring)
• Spring 6 credit hours (fails 3 credits)
• Summer 6 hours

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Case Study 2 Merged with Term Pell Formula 1

• Fall 1 half-time withdrew before census date
  ½ X 2,000 1,000
• Spring three-quarter time with intersession
  credits ½ X 1,500
• Summer half-time ½ X 2,000 1,000
• ½ used because there are two terms

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Case Study 2 Merged with Term Direct Loan

• Loan originated for Fall through Spring
• 2nd Disbursement made for start of intersession
  as part of second term
• Remaining annual loan limit eligibility used for
  summer
• New academic year for loan limit begins following
  Fall term

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Other Considerations for Intersessions

• Must apply same treatment in an eligible program
  for all Title IV
• If merged, must merge with same term for all
  students in program for all Title IV
• Whether merged or not, must adjust COA for
  loans/campus-based for a period of non-attendance

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Other Considerations for Intersessions

• If not merged
• - under 674.16 and 676.16 for Perkins
  and FSEOG, if student incurs uneven costs
  (e.g., short intersession) is a reduced payment
  for that payment period)

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Other Considerations for Intersessions

• If merged
• - census date for Pell recalculation
  may need to be reconsidered
• - may support loan eligibility for otherwise
  ineligible term
• - earliest Spring disb. date shifts with Spring
  and non-attendance

49

• R2T4 Regulations Affecting Modules

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Current Rules 34 CFR 668.22

• When a recipient ceases attendance before the
  scheduled end of the program for which s/he
  received Title IV, HEA aid
• The institution is required to determine the
  amount of aid that the student earned
• The institution also determines the unearned
  portion

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Prior to 7/1/11

• Rules did not specifically deal with term-based
  programs with courses that are less than the
  length of the term
• GEN-00-24 (Dec. 2000) we said when a student
  is in a modular program within a standard term
  and the student completes at least one of the
  modules, then R2T4 does not apply
• Completing one compressed course is the
  equivalent of completing a single course that
  spans the entire PP or POE

52
GEN-00-24 (Dec. 2000)
Session 1
Session 2
Session 3
WD Withdrawal after completing
Session 1 and after beginning Sessions 2 and 3.
53
Program Integrity Final Regulations (75 FR
66832) 10/29/10

• Return of Title IV funds topics
• Programs offered in modules
• When a student is considered a withdrawal
• Written confirmation
• Institution that is required to take attendance
• Academically-related activities

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R2T4 Definitions (eff. 7/1/11)

• Offered in modules
• If a course does not span the entire payment
  period (PP) or period of enrollment (POE)

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Offered in Modules

• If the student ceases attendance before the
  period for which aid was awarded, it is a
  withdrawal
• The denominator of the return calculation
  includes the full number of days used to
  determine the aid award, absent any
  institutionally scheduled breaks of five or more
  consecutive days or periods of time that the
  student was on an approved LOA

56
When a Student is Considered a Withdrawal
(effective 7/1/11)

• In a program measured in credit hours
• Student does not complete all the days scheduled
  to complete in the PP or POE
• In a program measured in clock hours
• Student does not complete all the clock hrs wks
  of instructional time scheduled to complete in
  the PP or POE

57
When a Student is Considered a Withdrawal
(effective 7/1/11) (cont.)

• In a non-term or non-standard term
• Student is not scheduled to begin another course
  within a PP or POE for more than 45 calendar days
  after the end of the module the student ceased
  attending
• Unless the student is on an approved LOA

58
Written confirmation effect. 7/1/11

• For courses offered in modules
• A student is not considered to have withdrawn if,
• For standard term programs, the institution
  obtains written confirmation that the student
  will return to complete a later module within the
  same PP or POE
• For non-term and non-standard terms the
  institution obtains written confirmation that
  module begins no later than 45 calendar days
  after the end of the module the student ceased
  attendance

59
Written confirmation eff. 7/1/11- (cont.)

• Student can revise the date of return to a later
  module, if
• Student does so in writing, between the time of
  the withdrawal, but prior to the return date
• For non-term and non-standard term programs, the
  later module begins no later than 45 calendar
  days after the end of the module the student
  ceased attendance

60
Written Confirmation eff. 7/1/11- (cont.)

• What happens when a student does return to a
  later module within the same PP or POE?
• If this is a non-term program, the student
  reenters the same program student is eligible
  for the same amount of Title IV, HEA funds prior
  to WD
• As long as the student returns within 180 days
  TIV is restored
• (see 668.4(f))

61
Institution Required to Take Attendance

• An outside entity (accreditor, state) has a
  requirement to take attendance
• (No change this is the current rule)
• If the outside entity has a requirement for
  attendance taking for a sub-group of students,
  then that sub-group are bound by the Institution
  required to take attendance rules in 668.22(b)
• If the outside entity has a requirement that
  attendance taking must occur for a limited time

62
Institution Required to Take Attendance eff.
7/1/11 (cont.)

• The institution has a requirement that attendance
  be taken
• The Program Integrity Final regulations do not
  require institutions to take attendance, however
• If an institution requires its faculty to take
  attendance at the program, departmental, or
  institutional level
• If there is no institutional requirement, but an
  individual faculty member chooses to take
  attendance, those records could, but would not be
  required to be used (Therefore, the institution
  is not required to take attendance 668.22(c))

63
Institution Required to Take Attendance eff.
7/1/11

• Institution or an outside entity has a
  requirement that can only be met by taking
  attendance for the program or a portion of the
  program
• Remember the regulations prior to July 1, 2011
  if an outside entity has a requirement that, as
  determined by the entity, the institution is
  required to take attendance

64
Institution Required to Take Attendance eff.
7/1/11

• If the institution is required to take attendance
  or requires attendance for only some students
• The attendance records must be used to determine
  the withdrawal date for that cohort of students

65
Institution Required to Take Attendance eff.
7/1/11

• If the institution is required to take attendance
  or requires attendance for a limited period of
  time
• The attendance records must be used to determine
  the withdrawal date for that limited period of
  time
• A student in attendance on the last day of the
  limited period, who subsequently WDs will be
  treated as a student at an institution not
  required to take attendance

66
Institution required to Take Attendance eff.
7/1/11

• Only required to take attendance for a single day
• Census snap-shot
• Not considered An institution required to take
  attendance
• Follow the rules in 668.22(c)

67
Academically-related activity Whats Included

• Examples of an academically-related activity
• Physically attending a class with direct
  interaction between the instructor and students
• Submitting an academic assignment
• Taking an exam, an interactive tutorial, or
  computer-assisted instruction

68
Academically-related activity Whats Included

• Examples of an academically-related activity
  (cont.)
• Attending a study group that is assigned by the
  institution
• Participating in an online discussion about
  academic matters
• Initiating contact with a faculty member to ask a
  question about the academic subject studied in
  the course

69
Academically-related Activity Whats Not
Included

• Effective 7/1/11 you can no longer consider the
  following an academically-related activity for
  R2T4 purposes -
• Living in institutional housing
• Participating in the institutions meal plan
• Logging into an online class without active
  participation
• Participating in academic counseling or advisement

70
EXAMPLES

• The next slides provide additional examples of
  the concepts just discussed

71
Offered in Modules - Example A

• Institution A
• Fall and Spring standard terms
• Never considered to be offered in modules
• Summer three 5-week sessions (combined to be a
  standard term)
• Students can enroll in any of the summer sessions
  or all of them
• Students enrolled in the 5-week summer sessions
  are considered in programs offered in modules
  since none of the sessions span the entire length
  of the term (the 15-week period)

72
Offered in Modules Example A

• Student 1 Enrolls in all three summer sessions
  and ceases enrollment on Day 5 in the first
  5-week session

73
Offered in Modules Example A

• The Results
• Step 1 Recalculate Pell Campus-based
• Step 2 Determine earned unearned amounts of
  Title IV aid (TIV)
• Numerator of days attended in Course 1
  (assume no breaks) 5 days
• Denominator Start date of Course 1 thru end
  date of Course 3 (less any scheduled break of 5
  or more consecutive days or approved LOAs) 105
  days or .048 or 4.8

74
Offered in Modules Example A
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
Withdrawal Day 5
75
Offered in Modules Example A
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
Withdrawal Day 5 student also drops remaining
sessions. Institution Required to Take
Attendance WD Day 5. Denominator 105 days.
Per GEN 04-12, the institution must have a
process to make this determination no later than
14 days after the LDA. Institution not Required
to Take Attendance WD 668.22(c). Denominator
105 days.
76
Offered in Modules Example A

• Student 2 Enrolls in all three summer sessions
• Day 4 of session 1, drops session 2
• Day 8 of session 1, withdraws during the first
  5-wk session
• Student does not provide written confirmation of
  return within the payment period

77
Offered in Modules Example A

• The Results
• Step 1 Recalculate Pell Campus-based
• Step 2 Determine earned unearned amounts of
  TIV
• Numerator number of days attended (assume no
  breaks) 8 days
• Denominator 35 days each in sessions 1 3,
  less any scheduled breaks or approved LOAs 70
  days or .114 or 11.4

78
Offered in Modules Example A
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
Day 4 drops Session 2
Day 8 - Withdraws
79
Offered in Modules Example B

• Summer sessions include three 5-week sessions and
  15-week sessions

80
Offered in Modules Example B
Session 5 week
Session 5 week
Session 5 week
Session 15- week
Student C enrolls in two 15-week courses this
student is not considered to be enrolled in a
program offered in modules.
Student D enrolls in one 5-week module and one
15-week course this student is considered to be
enrolled in a program offered in modules.
81
Offered in Modules Example C
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
1 wk break
1 wk break
Claire begins Module 1 in a non-term program, but
drops Session 2 on Day 3. Then she withdraws on
Day 5. She indicates that she wants to resolve
some health issues and then return at the
beginning of Session 3. What is her withdrawal
date?
82
Offered in Modules Example C
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
1 wk break
1 wk break
Claire drops Session 2. What is Claires
withdrawal date? Day 5 while it will be 79 days
before Session 3 begins, it is 49 days after the
end of the Session 1 until the start of Session
3, therefore a written confirmation is not an
option (greater than 45 days).
83
Offered in Modules Example C
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
1 wk break
1 wk break
Claires other option would be to seek a Leave of
Absence beginning on Day 6 of Module 1 and ending
the day before Session 3 begins.
84
Offered in Modules Example D

• The Results
• Step 1 Recalculation Campus-based has revised
  COA changed CB eligibility?
• Pell is NOT recalculated for non-term modular
  program since it is always based upon full time
  schedule
• Step 2 No return calculation due to the fact
  that the student provides written confirmation of
  her/his planned return between the time of the
  withdrawal and before the start of the third
  module

85
Offered in Modules Example D
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
Day 4 drops Session 2 Day 5 withdraws from
Session 1 and provides written confirmation that
student will return to Session 3.
86
Written Confirmation

• Student 3 Enrolls in all three summer
  sessions, drops session 2 on Day 4. Ceases
  enrollment on Day 5 in the first 5-week session,
  but provides written confirmation of future
  return

86
87
Written Confirmation eff. 7/1/11- (contd)

• What happens when the student doesnt return for
  the future module?
• The withdrawal date (WD) is -
• At an institution required to take attendance
  the last date of attendance (LDA)
• At an institution not required to take attendance
  midpoint or the last date of an
  academically-related activity

88
Written Confirmation
Session 1 5 weeks
Session 2 5 weeks
Session 3 5 weeks
35 days
35 days
35 days
Day 4 Withdraws from Session 1 and 2, but
provides written confirmation of return to
Session 3.
Day 71 Student does not return. WD Day 4 at
Institution Required to Take Attendance Midpoint
or Academically-related activity at an
Institution not Required to Take Attendance.
89
Institution Required to Take Attendance eff.
7/1/11
Term I 16 weeks
2 wks
Program A Daily attendance taking is required
for the first 2- week period.
All students who withdraw during the first 2 wks
Institution required to take attendance. All
students who withdraw after the 2-wk period
Institution not required to take attendance.
90
Total of Days in a PP or POE eff. 7/1/11

• Includes all the calendar days within the period
  that the student was scheduled to complete,
  except
• The number of institutionally scheduled breaks of
  five consecutive days or more are not included in
  the total calendar days used in the return
  calculation, or
• The days in which the student was on an approved
  LOA

91
Program Offered in Modules eff. 7/1/11

• For programs offered in modules the total
  number of days does not include
• The days a student was on an approved LOA
• Any institutionally scheduled break of five or
  more consecutive days when the student was not
  scheduled to attend a module or other course
  offered during that time

92
Program Offered in Modules eff. 7/1/11
Module 1
Module 2
Module 3
Student enrolls for three modules within a term
each 35 days in length and with a weekend in
between modules 1 2 and 2 3. Cheryl begins
and completes Module 1 and doesnt return for
Modules 2 3 and doesnt contact the
institution. Institution Required to Take
Attendance WD LDA- last day she took a final
exam. The denominator 109 days (35 x 3, plus 4
days between Modules). Institution not Required
to Take Attendance WD midpoint or last date
of an academically-related activity. The
denominator 109 days (35 x 3, plus 4 days
between Modules).
93
Program Offered in Modules eff. 7/1/11
Module 1
Module 2
Module 3
Student enrolls for three modules within a
standard term each 35 days in length and with a
week in between modules 1 2 and 2 3. Anthony
begins and completes Module 1 and doesnt return
for Modules 2 3 and doesnt contact the
institution. Institution Required to Take
Attendance WD LDA- last day he took a final
exam. The denominator 105 days (35 x 3). The
time between the Modules are more than 5
consecutive days and therefore excluded. Instituti
on not Required to Take Attendance WD
midpoint or last date of an academically-related
activity. The denominator 105 days (35 x 3).
94
Academically-related activity

• Please Remember!
• These events determined to be an
  academically-related activity must be documented
  and retained by the institution in accordance
  with the recordkeeping requirements in 34 CFR
  668.24
• Student self-documentation of an
  academically-related activity will not meet the
  requirement

95

• QUESTIONS ???

96
Contact Information

• Pamela Moran
• Office of Postsecondary Education
• 202-502-7732
• Pamela.Moran_at_ed.gov
• Dan Klock
• Federal Student Aid
• 202-377-4026
• Dan.Klock_at_ed.gov