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Ensuring High School Diploma Validity: Guidelines and Regulations

Learn about verifying high school diplomas, retaking coursework, and avoiding misrepresentation in educational institutions. Get insights on incentive compensation rules and maintaining program integrity standards.

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Ensuring High School Diploma Validity: Guidelines and Regulations

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  1. Program Integrity Miscellaneous Topics

  2. Evaluating the Validity of High School Diplomas

  3. High School Diploma • School must develop and follow procedures to evaluate the validity of a student’s high school diploma • If the school or the Department has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education §668.16(p)

  4. High School Diploma • New question #27 on 2011-2012 FAFSA • What is the name of the high school where you received or will receive your high school diploma? • High school name, city, and state • Department will maintain list of high schools populated by National Center for Education Statistics (NCES)

  5. Definition of a Full-Time Student: Retaking Coursework

  6. Retaking Coursework • Allows repeated coursework to count towards a student’s Title IV enrollment status in term-based programs • Allows a single repetition of previously-passed coursework • Does not allow for repeated coursework due to failure of other previous coursework §668.2

  7. Incentive Compensation

  8. Incentive Compensation • Adds new definitions • Commission, bonus, or other incentive payment • Securing enrollments or the award of financial aid §668.14 (b)(22)

  9. Incentive Compensation Examples of covered activities: -Recruitment – solicitations, contacting potential students, assisting prospective students in completing enrollment applications, targeted information dissemination -Financial Aid - completing financial aid applications for prospective students, including FAA Access tool

  10. Incentive Compensation Examples of exempt activities: -Recruitment – advertising to groups of prospective students, collecting contact information, determining whether an enrollment application is ‘materially complete’ -Financial Aid – general student counseling, financial aid counseling, online course support, tutoring

  11. Incentive Compensation A school must not provide any • commission, bonus or other incentive payments • based directly or indirectly on success in securing enrollments or financial aid • to any person or entity engaged in student recruiting or admissions activities, or in making decisions about the awarding of student financial assistance §668.14(b)(22)

  12. Incentive compensation A school, its contractor, or other entity may make merit-based compensation adjustments that are NOT based in any part, directly or indirectly, on success in securing enrollments or awarding financial aid §668.14 (b)(22)

  13. Incentive Compensation • Profit-sharing payments cannot be made to any person engaged in student recruitment or admission activity, or in making decisions about Title IV funding awards if based on number of students enrolled due to the covered activities of that person

  14. Incentive compensation • If an employee receives multiple compensation adjustments in a calendar year and is engaged in any student enrollment or admission activity, or in making decisions about Title IV awards, this will be considered to be a violation IF those adjustments are based on these activities in any manner. §668.14(b)(22)

  15. Incentive Compensation • This restriction does not apply to the recruitment of foreign students living in foreign countries who are not eligible to receive federal student aid. §668.14(b)

  16. Misrepresentation

  17. Misrepresentation • Program integrity principles • A potential student needs to have a clear understanding of any program in which he may enroll. • A school is responsible for providing complete and accurate information about its programs.

  18. Misrepresentation Requirements of HEA and regulations • A school must not make any substantial misrepresentation regarding the following: • Nature of its educational programs • Financial charges to students • Employability of its graduates §668.72-74

  19. Misrepresentation • Definition expanded • Any false, erroneous, or misleading statement • Made directly or indirectly • To a student, prospective student or any member of the public, or • To an accrediting agency, to a State agency, or to the Department • By. . . §668.71

  20. Misrepresentation • Definition (cont’d) • an eligible school • one of its representatives, or • any ineligible school, organization, or person with whom the eligible school has an agreement to provide educational programs, or to provide marketing, advertising, recruiting or admissions services §668.71

  21. Misrepresentation • Misleading statement includes any statement that has the likelihood or tendency to deceive or confuse • Substantial misrepresentation still includes any misrepresentation on which the person to whom it was made could reasonable be expected to rely, or has reasonably relied, to that person’s detriment §668.71

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