Spring 2011 issue of Horizons

Colleges & Universities – continued

Taking Attendance Clarification as to the types of institutions that are now required to take attendance is also covered in the new rules. Under previous policy, institutions that are required to take attendance only do so when the requirement is imposed by an outside entity. Under revised rules, institutions are now required to take attendance if they meet any of the following criteria: • An outside entity (such as the institution’s accrediting agency or a state agency) has a requirement that the institution take attendance. • The institution itself has a requirement that its instructors take attendance. • The institution or an outside entity has a requirement that can only be met by taking attendance or a comparable process, including, but not limited to, requiring that students in a program demonstrate attendance in the classes of that program, or a portion thereof. The effect of this rule is that any institution that requires its faculty to take attendance on its own (that is, without the request of an outside agency) is now subject to rules for institutions that are required to take attendance. For institutions that only require faculty to take attendance for a limited period of time (for instance, during the beginning of a semester), the department would require the institutions to use those records to determine a last day of attendance for students who withdraw during the period. For institutions that are deemed to be “required to take attendance,” this rule change could have a significant impact on the processing of Returns of Title IV Funds. Disbursement of Title IV Funds This rule change seeks to ensure that students with Title IV credit balances are able to obtain books and supplies at the beginning of a payment period.

The rules allow for the early payment of anticipated credit balances to Pell Grant-eligible students for this purpose. The final rules state that an institution must provide a way for a Federal Pell Grant-eligible student to use any anticipated credit balance (when Title IV funds are applied) to purchase books and supplies by the seventh day of a payment period if, 10 days before the beginning of the payment period, the institution could disburse the Title IV program funds for which the student is eligible. Gainful Employment The Department of Education has finalized a large portion of legislation related to proprietary and postsecondary vocational schools providing prospective students with information related to graduation and job placement within their eligible programs. These rules will apply to most educational programs offered by proprietary institutions that are eligible for Title IV funds because they prepare students for “gainful employment in a recognized occupation.” The regulations state that programs offered by public and nonprofit programs that are at least one academic year in length and lead to a “certificate, degree, or other recognized educational credential” are also subject to these regulations because they prepare students for “gainful employment in a recognized occupation.” In consideration of these provisions, the programs offered at many public and nonprofit colleges and universities will need to comply with the same rules that apply to proprietary institutions. Gainful employment rules state that institutions must disclose to prospective students the following information: • The names and occupations that the program prepares students to enter • The on-time graduation rate for students completing the program

Raise Your Expectations

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