Due to this recent federal audit finding, UC Merced must implement a mechanism to verify that undergraduate and graduate students begin attendance in each of their courses per term. Furthermore, the auditor stipulated that it is not the student’s responsibility to certify their own attendance, there must be a faculty certification component integrated into our solution.
With the assistance of IT, we are developing a solution that offers multiple ways to confirm student academic activity by Census Day (i.e., 15th day of instruction) for each course with minimal faculty involvement.
We are hoping to pilot this solution in Summer 2021, with a full implementation commencing in the 2021/22 academic year. UC Merced will recalculate financial aid after Census for all undergraduate and graduate recipients based on their enrollment status in those classes which we can confirm that the student actually began attendance. If we are unable to document the student’s academic activity in a class, aid will be adjusted to exclude the units for that class. Student will have an opportunity to appeal if they have supporting documentation from the instructor confirming their attendance.
We are also developing a communication plan that will include disseminating information about Academic Activity resources that will be placed on the Registrar, Financial Aid, and a project website including regulatory information, reporting tutorials, and how to submit an appeal.
In March 2019, Provost Brown requested that each UC campus submit a plan to confirm the commencement of student academic activity at the beginning of each term for the purposes of complying with federal student aid regulations associated with recent Program Review audit findings at the Davis and Merced campuses.
The context for the findings is typically for students who end a term with all “F” grades, which the University must then document their last date of attendance. Until recently, campuses did this by following up after the end of the term. However, UC Merced program reviewers specifically cited the following regulations to demand that the documentation happen early in the term.
The critical citation is the last, where academic activity is defined. The full text of this section is below. Emphasis is added for the discussion of the proposed solution below.
The school (not the student) must document:
(7)(i) ‘‘Academic attendance’’ and ‘‘attendance at an academically-related activity’’—
(A) Include, but are 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
(B) Do 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.
Subregulatory guidance in the form of the Federal Student Aid Handbook makes it clear that taking attendance is not strictly required by this section. In fact, the UC pointed to its status as an institution “not required to take attendance” as a rationale for its previous approach. However, ED has also made clear that, despite not being required to “take attendance,” UC is still subject to the above regulation.
Language included in the aforementioned proposed rulemaking process from 2000 further clarifies ED’s intent:
We propose to modify those requirements by specifying that academic engagement includes active participation by a student in activities related to their course of study, such as an online course with an opportunity for interaction or an interactive tutorial, webinar, or other interactive computer-assisted instruction. It does not include, for example, simply logging into an online platform. Such interaction could include the use of artificial intelligence or other adaptive learning tools so that the student is receiving feedback from technology-mediated instruction. (See here, emphasis added.)
