Online Programs: Challenges and Solutions

1. Online Programs: Challenges and Solutions Melody DeFlorio May 18, 3014

2. Goals

3. Distance Education Courses HEA Sec. 103 and 484(I) 34 CFR 600.2, 668.38 Distance education refers to instruction delivered to students who are physically separated from their instructor, to support regular and substantive interaction between student and instructor, whether in real time or through time delay

4. Distance Education Challenges

5. Verification • Educational Purpose • Identity • Citizenship • Unusual enrollment History

6. Identity and statement of educational purpose For students selected for verification tracking group 5: “A student who is unable to appear at the school must sign and submit the statement of educational purpose, and he must submit a copy of his ID with the statement signed by a notary public confirming that the student appeared before her and presented the ID confirming his identity” For students who are flagged in the V6 group who only qualify for non-need based aid, the verification of identity/educational purpose is not required.

7. Citizenship – US Citizens

8. Citizenship – Eligible Noncitizens

9. Challenges:

10. Solutions

12. Enrollment status Challenges

13. Enrollment status Challenges

14. ‘Classroom’ Activity • Confirming Participation • Nonterm programs • Module based programs • Change in enrollment status: student vs institution at fault • Add/drop policy: working with or against disbursement and refunding policies

15. Are you an institution required to take attendance? From FSA Handbook, Volume 6, Chapter 1 • Discussion Posts • Group Projects • Submitting weekly assignments • Administrative withdraw policy

16. R2T4 and Overawards • Problem: • Higher risk of overaward/overpayment • Solutions: • Routine monitoring of attendance • Routine monitoring of enrollment status, particularly for module-based programs

17. Cost of Attendance

18. Allowable COA Costs Tuition and Fees Books, supplies Transportation Miscellaneous Room and board Dependent care Disability care Loan fees Exceptional Expenses*

19. Allowable COA Costs

20. COA considerations Student by student considerations: Student unemployed? Do they have daycare expenses? Where do they live? Internet/computer costs Aggregate borrowing: sustainable? Institutional considerations: Distance learners must be treated same way as traditional learners COA must be same for all students in same program Room and board component should be adjusted for less than half time enrolled students

21. COA Resources College Board IPEDS NASFAA Tools EASFAA Peers Survey Monkey

22. Fraud

23. Fraud OIG Audit Findings: Colleges disbursed $222 million in aid to more than 42,000 online students who did not earn credits during a payment period

24. Fraud OIG’s IPAR: Distance Education Fraud Rings L42L0001 “Education programs that are delivered solely through the Internet present unique opportunities for fraud and challenges for oversight, because Title IV programs were designed to deliver aid to students who are physically present in traditional classrooms, rather than alternative on-line environments”

25. Fraud Challenges • Distance Education Programs growing quickly • Verification of Identity is not required • Refunds

26. Fraud Solutions Verification of Student Identity Aligning disbursement/refund schedule with add/drop schedule NSLDS and CPS flags for potential fraud activity Monitor classroom activity

27. Shared Experiences Other Challenges Questions? Melody DeFlorio mdeflori@norwich.edu 802-485-2019