TASFAA Annual Conference TASFAA Annual Conference

20102010

Galveston, TexasGalveston, Texas

So What?

The Higher Education Act of 1965, as amended, requires an institution of

higher education participating in the Federal student aid programs to admit

as regular students:

Only persons who have obtained a high school diploma or its

recognized equivalent (or are beyond the age of compulsory

school attendance).

In order to be eligible to receive Title IV aid, a student must:

1. Have a high school diploma or its recognized equivalent, or2. Completed secondary school in a home school setting, or 3. Pass an independently administered examination approved by the Secretary, or4. Successfully complete 6 credits at own expense

There is a regulatory definition of the “recognized equivalent of a

high school diploma,”

HOWEVER,

the term “high school diploma” is not defined in regulations.

A student may self-certify on the FAFSA that he has

received a high school diploma or GED or that he has completed secondary

school through homeschooling as defined

by state law.

If a student indicates that he has a diploma or GED, the postsecondary institution isn’t required to ask for a copy.

Basically, if a student does not have a high school diploma or GED and has not completed secondary school through home schooling, the student will have to pass an Ability-to-Benefit test to qualify for student aid.

If the institution requires a HS Diploma or GED for

admission, the institution must rely on that copy of the diploma or GED and not on the student’s certification

alone.

Confirming the authenticity of a student’s high school experience has become more difficult in part due to the proliferation of high school diploma mills.

Institutions that have concerns about the validity of a diploma from a particular school often check with the department of education for the state in which the school is located.

If the state department or agency has jurisdiction over the high school, it can confirm whether a diploma from the school (which does not have to be accredited) is recognized by the state.

Not all states have a means of recognizing even all the legitimate high schools operating in their state, particularly private high schools.

Who Cares?( at least the GAO)

The Government Accountability Office, in an August 2009 report found a “growing problem” and recommended to ED that the Department have a clearer, official policy about high school diploma mills.

For Whom The Problem Exists?

Primarily, but not exclusively public Two Year Community Colleges and private For Profit Institutions who do not require a copy of the HSD or GED document for admissions to the school.

1.Consistency of information provides “cover”2.Inconsistent information uncovers the problem3.Conflicting information must be resolved4.There in “lies” the problem5.Collecting documentation and verifying it’s legitimacy

CASE STUDY

The student completed the 2008-09 FAFSA in August of 2008 and answered the “do you have a HSD or GED” yes, which is the

same answer they provided on the college’s admissions application. The public Two Year Institution does not require

submission of that document for admission so none was collected. Self reported on both applications.

No confirmation required.

No problem.

File awarded Pell and the student took out a loan.

The same student completed the 2009/10 FAFSA in March of 2009; but, this time the answer to the same question was no. This caused conflicting information which prompted a “request for documentation” letter requiring the student to submit a copy of the HSD/GED before the file could be awarded for 2009/10.

Problems, we have problems, lots and lots of lots of problems.problems.

Student submitted copy of the HSD from an “on Student submitted copy of the HSD from an “on

line” out of state company. A review of the line” out of state company. A review of the company's web site revealed that while the company's web site revealed that while the

document said, “High School Diploma,” they were document said, “High School Diploma,” they were actually a GED prep operation, not a HS degree actually a GED prep operation, not a HS degree

program. The student paid hundreds, was issued the program. The student paid hundreds, was issued the document but never sat for the GED.document but never sat for the GED.

Life After The Final Regs Are Published

Team 1 reached consensus on this issue but because consensus was NOT reach on all issues ED

may present different language. If they follow through with what was agreed to it will look like

this:

Beginning with the 2011-12 award year, a student completing the Free Application for Federal Student Aid (FAFSA) will be required to list the name of the secondary school or

entity that provides a secondary school program of study and the state that awarded

his or her high school diploma.

If the secondary school or entity the student provides does not match the list of secondary schools maintained by the Department or if the student does not provide the name of the secondary school or entity or the state that issued the diploma, ED may flag the student's FAFSA for further review by the institution to determine if the student has a valid high school diploma before the student can receive any Title IV aid.

The Department will provide guidance, most likely in the FSA Handbook, to help schools evaluate the validity of a high school diploma for purposes of awarding Title IV aid.

The proposed regulatory language consists only of an addition to the standards of administrative capability, whereby a school must "develop and follow procedures to evaluate the validity of a student's high school completion if the institution or the Secretary has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education."

What is Ability to Benefit (ATB)?Students must possess:

High school Diploma, GED Recognized equivalentOR, PassIndependently administeredU. S. Department of Education approved

test of basic math and English skills,

How ATB testing worksED overseeing test publishersTest publishers certify and monitor test

administrators to ensure:Independence Proper administration

Independent Test Administrators (ITA):• Proctor tests• Submit answer sheets directly to Test

Publisher

Current Regulations:• Test publishers submit

analysis to EDto identify test

irregularitiesonce every three yearsno follow up required

GAO Findings:Lack of monitoring of ATB testing byEDTest PublishersSchool Officials

Oversight Needed

GAO Study – 2 RecommendationsImprove monitoring of Ability To Benefit tests

Revise regulations to strengthen controls

NPRM – 6 credit hours/225 clock hours (668.32 (e))

Add “satisfactory completion of 6 credit hours” (HEA provision)

Students may not receive aid for this coursework, and

Students may not receive aid retroactivelyCoursework must be in an eligible

program6 quarter/semester or 225 clock hours

NPRM: States and Test Publishers (668.141 – 668.156)

Must have process to follow up on test irregularities

Take corrective actionReport decertified test administrators

NPRM: Independent Test Administrator (668.142)

Add definition to regulationsNo current or prior financial or ownership

interestNot a current or former employeeNot a current or former member of the

board of directorsNot a current or former student

NPRM: Agreements – Test Publisher and State (668.150)

In response to the GAO report:Rigorous certification and decertificationTest score analysis every 18 monthsNotify ED, ITA and the school

Decertification of ITANotify Schools/Students – improper testNotify ED -- compromised tests

NPRM: Institutional Accountability (668.154)

Schools are liable:

Test not independently administered

School or employee compromised test

Cannot document test score

Special Thanks

Rich Heath

Anne Arundel Community College

Elaine Neely

Kaplan University

QUESTIONS?